Full text: Controlling Fentanyl-Related Substances – China's Contribution

IV. Enforcing Strict Control over Precursors of Fentanyl-Related Substances

China has established complete legal and administrative systems for scheduled precursor chemicals. It has also formed a regulatory system based on the Regulations on the Administration of Scheduled Precursor Chemicals, and supported by the Measures on Licensing the Production and Sale of Scheduled Non-pharmaceutical Precursor Chemicals, Measures on the Administration of the Purchase, Sale, and Transportation of Scheduled Precursor Chemicals, Measures on the Administration of Scheduled Pharmaceutical Precursor Chemicals, Regulations on the Administration of the Import and Export of Scheduled Precursor Chemicals, and Regulations on the Administration of International Verification of the Import and Export of Scheduled Precursor Chemicals. 

Authorities in charge of public security, commerce, emergency management, public health, customs, and medical products administration expand the control list of precursors of fentanyl-related substances and supervise their production, sales, purchase, transportation, and export in accordance with their respective responsibilities.

– Expanding the control list effectively and responsibly. Taking into consideration production needs and the risk of misappropriation, China places chemicals that could be used to manufacture fentanyl-related substances on the control list of scheduled precursor chemicals in a timely manner. The following five types of precursors have been brought under control: 4-ANPP, NPP, 4-AP, 1-boc-4-AP, and norfentanyl, and all precursors of fentanyl-related substances that were on the United Nations control list before 2024 have been covered. Work on scheduling 4-piperidone and 1-boc-4-piperidone, which the United Nations added to its control list in 2024, is underway.

– Adopting multi-level and category-specific supervision. In accordance with the Regulations on the Administration of Scheduled Precursor Chemicals, 4-ANPP and NPP are managed as Class I scheduled precursor chemicals. Enterprises applying for their production and sale must be approved by the emergency management departments of provincial-level governments. Applications for their purchase must be approved by the public security departments of provincial-level governments, and applications for their transportation must be approved by the public security departments of governments of cities (with districts). Substances like 4-AP, 1-boc-4-AP, and norfentanyl are managed as Class II scheduled precursor chemicals. Within 30 days from their production and sale, manufacturing enterprises must report the type and quantity of the chemicals they produce, and trading enterprises must report the type, quantity and main destinations of the chemicals they sell, among others, to the local emergency management departments of governments of cities (with districts), and their purchase and transportation must be approved by the local public security departments of county-level governments.

– Strictly supervising exports. For the five types of precursor chemicals already under control, a strict approval, permit, and international verification system is in place. Before the Ministry of Commerce examines applications for export permits, the Ministry of Public Security sends a verification request to the competent authorities of the importing country through the International Narcotics Control Board (INCB)'s Pre-Export Notification (PEN) Online system. After receiving the feedback verifying the legality of the transaction, the Ministry of Commerce issues permit in accordance with the law. The customs departments proceed with export clearance with declaration documents and the export permit. Since establishing control over the five aforementioned precursors, there has been no recorded application for export by Chinese enterprises. 

– Realizing closed-loop supervision through informatization. A national management system for precursor chemicals has been established, available free of charge to enterprises, enabling the collection of all data for the management of scheduled precursor chemicals in China through one platform. The Ministry of Public Security and 10 other departments issued the Guidelines on the Establishment of a Digital Tracking System for Scheduled Precursor Chemicals to achieve dynamic and full-process monitoring of their production, sale, purchase, transportation, import, and export by building a supervision system for the identification and traceability of scheduled precursor chemicals. At the same time, emphasis has been placed on the role of industry associations and a credit rating system has been implemented to promote self-discipline among enterprises.

As the international community invests more effort in implementing the 1988 Convention, controlled chemicals have become more difficult to obtain. Lawbreakers abroad are constantly updating drug-manufacturing techniques, and more often using uncontrolled chemicals to manufacture drugs, especially by exploiting the differences in chemical control laws between countries. They purchase uncontrolled precursors of fentanyl-related substances online via virtual currency payment and international parcel delivery to evade regulatory scrutiny. This has become a prominent challenge for governing fentanyl-related substances. China pays close attention to this issue, and has adopted a series of strong measures such as monitoring and early warning, online inspection, prioritizing key areas, and circulating notifications, to prevent the flow of uncontrolled chemicals into illegal overseas channels.