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Updated September  28, 2023


China Primer: Illicit Fentanyl and China's Role


Addressing illicit fentanyl in the context of the ongoing
opioid crisis in the United States is a domestic and foreign
policy issue for Congress. In addressing the international
dimension of the problem, policymakers have endeavored
to stop foreign-sourced fentanyl, fentanyl-related
substances (i.e., analogues), and chemical inputs (i.e.,
precursors) from entering the United States. Early in the
U.S. opioid epidemic, the People's Republic of China
(PRC, or China) was the primary source of illicit fentanyl,
but such direct flows have reportedly ceased. U.S.
counternarcotics policy with regard to China has shifted to
preventing PRC-sourced fentanyl precursors from entering
the U.S.-bound fentanyl supply chain via third countries,
and targeting illicit fentanyl-related financial flows linked
to China. U.S.-PRC cooperation on drug control issues has
been severely strained since 2020.

Background
Fentanyl is a potent synthetic opioid that has been used
medically as a painkiller and an anesthetic since it was first
synthesized in 1959. Due to fentanyl's potential for abuse
and addiction, the United Nations (U.N.) placed it under
international control in 1964. Domestically, fentanyl is
regulated by the Drug Enforcement Administration (DEA),
pursuant to the Comprehensive Drug Abuse Prevention and
Control Act of 1970, as amended (21 U.S.C. §§801 et seq.).
Controlling the production and trafficking of fentanyl and
its analogues has emerged as a major international drug
policy concern for the United States. The U.S. Centers for
Disease Control and Prevention estimates that synthetic
opioids (primarily fentanyl-related substances) may have
resulted in more than 77,000 overdose deaths between May
2022 and April 2023. Moreover, traffickers appear to be
marketing a growing number of fentanyl analogues for
nonmedical, often unregulated, use.

In November  2021, the International Narcotics Control
Board-an   independent expert body that monitors
governments' compliance with U.N. drug control treaties-
reported the existence of more than 150 fentanyl-related
substances with no currently known legitimate uses. The
U.N. Office on Drugs and Crime estimates that laboratories
could potentially synthesize thousands of other fentanyl
analogues. As of May 2023, more than 30 fentanyl-related
substances, including precursors, are scheduled for
international control pursuant to the U.N. Single
Convention on Narcotic Drugs of 1961, as amended, and
the U.N. Convention Against Illicit Traffic in Narcotic
Drugs and Psychotropic Substances of 1988.

U.N. member  states first subjected fentanyl precursors to
international control in 2017, agreeing to list the precursors
N-Phenethyl-4-piperidone (NPP) and 4-Anilino-N-
phenethylpiperidine (ANPP) on Table I of the 1988
Convention. (In February 2018, consistent with the U.N.


decision, the PRC implemented corresponding domestic
controls.) In March 2022, U.N. member states subjected
three more fentanyl precursors to international control: N-
Phenyl-4-piperidinamine (4-AP), tert-Butyl 4-
(phenylamino) piperidine-1-carboxylate (boc-4-AP), and
norfentanyl.

Sources and Trafficking Pathway
Prior to 2019, China was the primary source of U.S.-bound
illicit fentanyl, fentanyl-related substances, and production
equipment. PRC  traffickers supplied fentanyl and fentanyl-
related substances directly to the United States via
international mail and express consignment operations.
Trafficking patterns changed after the PRC imposed class-
wide controls over all fentanyl-related substances, effective
May  2019. Today, Mexican transnational criminal
organizations are largely responsible for the production of
U.S.-consumed  illicit fentanyl, using primarily PRC-
sourced materials, including precursor chemicals that are
not internationally controlled (and are correspondingly legal
to produce in and export out of China). According to recent
U.S. Department of the Treasury assessments, Mexican
cartels are increasingly working with PRC money
laundering organizations.

Fentanyl destined for nonmedical consumption may be
produced in clandestine laboratories. Pharmaceutical
preparations of fentanyl may also be diverted through theft
and fraudulent prescriptions. Legitimate chemical and
pharmaceutical companies produce fentanyl analogues and
precursors that are not domestically or internationally
regulated. In February 2022, the final report of the U.S.
Commission  on Combating  Synthetic Opioid Trafficking
(established pursuant to §7221 of P.L. 116-92), concluded
that the PRC's chemical and pharmaceutical sectors have
outpaced the government's efforts to regulate them,
creating opportunities for unscrupulous vendors to export
chemicals needed in their illegal manufacture.

Addressing Ch ina's RoIe
With respect to the PRC, the Joseph R. Biden Jr.
Administration's April 2022 National Drug Control
Strategy prioritizes increased collaboration on shared drug
priorities and continued engagement to reduce diversion
of uncontrolled precursor chemicals. In testimony before
the House in July 2023, Office of National Drug Control
Policy (ONDCP)  Director Rahul Gupta said that the United
States has adopted a multipronged approach to address
precursors from China. It includes raising precursor
diversion in every meeting with PRC counterparts and
working multilaterally to expand U.N. scheduling of
synthetic drugs. In July 2023, the United States also
launched a Global Coalition to Address Synthetic Drug
Threats, including fentanyl.


Wsson I Resedrch Service
   Ih leasaive dea si n'e 1914

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