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China’s approach to controlling fentanyl precursors has long been a point of contention. In August 2024, the country announced it would add three fentanyl precursors to its regulated list of precursor chemicals, enhancing oversight on their production, sale, purchase, transport, import, and export. This move, however, came more than two years after United Nations member states had already subjected the same three substances to international control. Critics argue this delay underscores China’s reluctance to take meaningful action against its role in the global fentanyl crisis.
When China finally acted, it was framed as progress. The Biden Administration described the scheduling of these chemicals as “a valuable step forward,” marking the third major regulatory action by Beijing since the resumption of bilateral counternarcotics cooperation in November 2023. Notably, the announcement came just two days after senior U.S. and Chinese officials met as part of the U.S.-PRC Counternarcotics Working Group on July 31.
Yet, many remain skeptical about the effectiveness of these measures. China’s new controls target only three fentanyl precursors, leaving hundreds of other precursors produced and exported by the country outside regulatory oversight. Compounding the issue, Chinese industrial policies, such as tax incentives for chemical and pharmaceutical manufacturers, have bolstered the production of illicit fentanyl precursors. Non-scheduled substances, which can be used for both legal and illegal drugs, also face minimal regulation. Moreover, the rapid emergence of new fentanyl variants presents a challenge, as these compounds often remain outside government control until long after they enter illicit markets.
Chinese companies have proven adept at evading regulations through operational shifts. Following Beijing’s 2019 decision to schedule the entire class of fentanyl drugs, chemical traders pivoted to selling precursor ingredients that fell outside regulatory frameworks. This adaptability highlights a persistent gap in China’s regulatory approach, leaving ample room for illicit production to continue.
China’s regulations on precursor chemicals include the following requirements:
- Report the production and sales information of precursor chemicals to local authorities.
- Apply for permits to transport precursor chemicals outside counties or cities.
- Apply for licenses to import or export precursor chemicals.
Prior to the notice, the Chinese government had scheduled controls on two fentanyl precursors, NPP and 4-ANPP, in 2018. Chinese-manufactured chemical precursors for illicit fentanyl have become a point of contention in U.S. efforts to curb the fentanyl trade from China and Mexico.
Media Highlight: “Latest Announcement! These 7 Substances Will Be Included in the Administration of Precursor Chemicals Starting September”
LINK: https://ev3.exovera-projects.com/media?share=c4ad4766-21e0-4f37-a001-37263cc5a3b5
On August 2, China’s Ministry of Public Security (公安部) and five other administrative agencies jointly issued a notice regarding the addition of seven substances including three fentanyl precursors to the 2005 “Regulation on the Administration of Precursor Chemicals” (易制毒化学品管理条例). Other agencies backing the notice are the PRC Ministry of Commerce (商务部), National Health Commission (国家卫生健康委员会), Ministry of Emergency Management (应急管理部), General Administration of Customs (海关总署), and National Medical Products Administration (国家药品监督管理局).
Three fentanyl precursor chemicals—4-AP, 1-Boc-4-AP, and norfentanyl—would be managed under the regulation from September 1.
According to the regulation, those that produce these precursor chemicals must report the type and quantity to local authorities within 30 days of production.
Those who do business in such precursor chemicals must report the type, quantity, and major sales flows to local authorities within 30 days of operation.
Businesses must create sales records of these precursor chemicals, specifying the type, quantity, date of sale, and purchaser, and maintain these records for at least two years. They must also report sales of these precursor chemicals to local authorities within 30 days of the date of transaction.
Individuals, enterprises, and other organizations must apply for permits to transport such precursor chemicals outside their county or city.
Entities must apply for licenses to import or export these precursor chemicals, showing proof of legal use of the precursor chemicals or that the importer is conducting legal business. Applicants for licenses may be subject to on-site inspections by local or central government authorities.
Exovera Commentary:
The Chinese government’s August 2024 decision to control and regulate three fentanyl precursors appears to be motivated by a desire to show its commitment to the renewed U.S.-China cooperation on counternarcotics. The latest measure, however, is unlikely to disrupt the country’s vastly unregulated production and distribution networks that supply precursor chemicals to Mexico for fentanyl production, or solve the U.S. fentanyl crisis.
The inclusion of the three precursors under China’s 2005 “Regulation on the Administration of Precursor Chemicals” creates new requirements for chemical producers and traders to report information to local authorities on the variety and quantity of these precursors being produced and sold, as well as to apply for permits to transport, import, and export them. The Chinese government, however, is not directly banning the wholesale production or export of these three fentanyl precursors.
As of December 2, 2024, at least seven Chinese companies continue to openly market two of the three fentanyl precursors—4-AP and 1-Boc-4-AP—that have recently come under Chinese government regulation. The following companies that manufacture these fentanyl precursors (identified with their location) are subject to Chinese government regulation:
- Hebei Hegui Biotechnology Co., Ltd. (河北合贵生物科技有限公司), Shijiazhuang
- Winchem Industrial Co., Ltd. (WINCHEM), Ningbo
- Xi An Rhine Biological Technology Co., Ltd. (RHINE, 西安绿洲生物科技有限公司), Xi’an
- Hangzhou Jeci Biochem Technology Co., Ltd. (JECI, 杭州杰细生化科技有限公司), Hangzhou
- Tianjin Liduomei Import and Export Co., Ltd. (天津利多美进出口有限公司), Tianjin
- Hoyan Pharmaceutical (Wuhan) Co., Ltd. (HOYAN, 红焰医药科技(武汉)有限公司), Wuhan
- Weihai Xiangyu Technology Co., Ltd. (威海翔宇环保科技股份有限公司), Weihai
The following are examples of advertisements of two fentanyl precursors—4-AP (N-phenylpiperidin-4-amine, CAS 23056-29-3) and 1-Boc-4-AP (1-N-Boc-4-(Phenylamino)piperidine, CAS 125541-22-2)—on Chinese company websites. The use of English in advertisements and product listings from these chemical companies is intended to appeal to a foreign audience.
Hebei Hegui Biotechnology Co., Ltd. advertises 1-Boc-4-AP (1-N-Boc-4-(Phenylamino)piperidine, CAS 125541-22-2) on its website.
Xi An Rhine Biological Technology Co., Ltd. sells 4-AP (N-phenylpiperidin-4-amine, CAS 23056-29-3) on its website.
Hangzhou Jeci Biochem Technology Co., Ltd. sells 1-Boc-4-AP (1-N-Boc-4-(Phenylamino)piperidine, CAS 125541-22-2) stating “safe delivery to Mexico, USA, [and] Canada” on its website.
Tianjin Liduomei Import and Export Co., Ltd. advertises 1-Boc-4-AP (1-N-Boc-4-(Phenylamino)piperidine, CAS 125541-22-2) on its website.
Hoyan Pharmaceutical (Wuhan) Co., Ltd. markets 1-Boc-4-AP (1-N-Boc-4-(Phenylamino)piperidine, CAS 125541-22-2) on its website.
Hoyan Pharmaceutical (Wuhan) Co., Ltd. sells 4-AP (N-phenylpiperidin-4-amine, CAS 23056-29-3) on its website.
