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July 18, 2016

Meth Precursor Chemicals from China: Implications for the United States

Sean O’Connor, Policy Analyst, Economics and Trade

Acknowledgments: The author thanks James Bosworth, members of the team at the Joint Interagency Task Force-West, officials at the U.S. Food and Drug Administration, and officials at the U.S. Drug Enforcement Administration for their helpful insights. Their assistance does not imply any endorsement of this report’s contents, and any errors should be attributed solely to the author.

Executive Summary

During the last 15 years, methamphetamine (meth) abuse in the United States has skyrocketed, necessitating new policies to reduce meth production. To limit the drug’s use, regulations were introduced in the mid-2000s limiting access to cold and cough medicines containing chemicals like ephedrine and pseudoephedrine—also known as “precursor” methamphetamine chemicals—used to produce meth. Nevertheless, meth seizures and abuse have
continued to increase, with Mexican drug organizations replacing domestic producers as the main manufacturers and distributors of meth in the United States. While Mexican cartels produce the majority (around 90 percent) of meth used in the United States, around 80 percent of precursor chemicals used in Mexican meth come from China. Precursor chemicals are increasingly being shipped from China to Mexico, where they are manufactured into meth, transported across the southern border of the United States, and brought into southwestern states—Texas, Arizona, and California—before being shipped across the country. A period of increased cooperation between the U.S. and Mexican governments in the late 2000s and early 2010s has done little to reduce the precursor flows, with Chinese drug traffickers circumventing counternarcotic authorities by shipping chemicals to poorly regulated Central American ports before transporting them to Mexico.

As China has become a global source of precursor chemicals, reports of meth abuse and meth lab incidents in China have also become more frequent. To combat rising meth use among Chinese citizens, large-scale drug busts have become more common during the last few years, particularly in coastal cities and towns. In addition, Beijing has introduced new drug regulations and enhanced cooperation with international counternarcotic organizations. Despite these efforts, China remains one of the largest global producers of meth precursor chemicals. China is home to the world’s second-largest pharmaceutical industry by revenue, producing and exporting vast quantities of generic drugs and active pharmaceutical ingredients (APIs) used to manufacture legal and illegal drug products. Coupled with the country’s large domestic consumer market, the scale of Chinese API production has led to lower costs for chemical production, which in turn has made China the world’s leading exporter of APIs. In addition, Chinese nonpharmaceutical chemical companies ship more than one-third of the world’s chemicals, making it the world’s largest chemical producer and exporter. The U.S. Department of State estimates that nationwide, China has more than 160,000 chemical companies operating legally and illegally, with facilities manufacturing tons of precursor chemicals every week. Ultimately, Chinese manufacturers of meth precursors have thrived because the country’s vast chemical and pharmaceutical industries are weakly regulated and poorly monitored. China’s drug and chemical regulators are unable to adequately inspect the country’s chemical producers, and online chemical sales have made it easy for drug producers to avoid detection. Furthermore, nonpharmaceutical chemical facilities have been poorly monitored, allowing producers to easily circumvent inspection requirements. The lack of regulations has led to an increasing number of unlicensed chemical companies—and, through them, effectively unlicensed pharmaceutical companies—producing illegal chemicals, making it easy for drug traffickers to gain access to precursors. Corrupt government officials also undermine China’s chemical regulations, with local regulators bribed to overlook illegal chemical production.

To reduce precursor chemical flows, the United States and the international community at large are working with China through an array of international and bilateral mechanisms, forming government working groups, establishing international drug tracking systems, and strengthening international precursor regulations. Yet, international laws governing chemical trade remain insufficient and are easily circumvented. There are numerous ways precursor exports can be hidden from regulators, including mislabeling chemical shipments, modifying illegal chemicals, and shipping legal pre-precursor chemicals, or the chemicals used to create precursors.

History of Meth Use in the United States

Despite crackdowns on ingredients necessary for meth production, meth abuse in the United States continues to grow. 1 Meth is a powerful, highly addictive Schedule II stimulant—meaning it is legally available only through a nonrefillable prescription—that drug users ingest, snort, smoke, or inject for recreational use. 2 Meth use increased steadily throughout the 1990s and early 2000s, with approximately 5 percent of the U.S. population ages 12 and older having used meth in their lifetime in 2004, up from 2 percent in 1994. 3 In 2004, nearly 24,000 meth laboratory incidents—instances where meth lab equipment or dumpsites were confiscated by authorities—were reported in the United States, an all-time high. 4 The drug’s growing prominence necessitated new policies limiting access to meth precursor chemicals—like ephedrine and pseudoephedrine—found in cold and cough medicines that can be used to produce meth (for a full list of U.S. controlled precursor chemicals, see Appendix I, “Controlled Chemicals in the United States”). 5

To reduce the availability of precursor chemicals, Congress enacted the U.S. Combat Methamphetamine Epidemic Act of 2005, setting sales limits for products containing precursor chemicals and requiring these products be sold behind the counter and entered into a national log. 6 In 2007, a full year after the Combat Methamphetamine Epidemic Act was implemented, the number of meth lab incidents decreased by 71 percent, and meth seizures declined by 33 percent (see Figure 1). 7 In the following years, however, meth seizures increased, rising 78 percent between 2004 and 2014, even as the number of meth labs in the United States has declined by 61 percent over the same period. 8 Although meth seizures declined 30 percent year-on-year in 2014, the U.S. Department of State’s 2016 International Narcotics Control Strategy Report (INCSR) indicates meth trafficking to the United States spiked again in 2015 (although official 2015 trafficking data are not available), which typically leads to a surge in domestic meth seizures.9

The 2015 National Drug Threat Assessment Summary by the U.S. Drug Enforcement Administration (DEA) concludes that while regulations on meth precursor chemicals have led to reduced U.S. meth production, increased availability of Mexico-produced meth has made Mexican drug organizations the primary manufacturers and distributors of meth in the United States. 10 Domestic meth labs continue to produce and distribute meth in the United States, but they operate on a much smaller scale compared to meth makers in Mexico, where the product is far cheaper and purer. 11 Lawrence Payne, a spokesman for the DEA, said “the days of the large-scale U.S. meth labs are pretty much gone,” with Mexico “tak[ing] over production south of the border and distribution into the United States.” 12 Increased meth seizures at the U.S.-Mexico border over the last few years appear to support Mr. Payne’s assessment: the U.S. Border Patrol reported meth seizures along the southern border increased from less than 0.5 kilograms (kg) in 2005 to nearly 773 kg in 2011; authorities in San Diego also saw a 43 percent increase in meth seizures between 2013 and 2014. 13 According to the DEA, meth shipments of 20 kg or more are regularly seized at the southwestern U.S. border. 14
Precursor Chemical Flows from China While Mexican cartels produce the majority of meth used in the United States, China is the main source of meth precursor chemicals: according to the DEA, Mexico produces around 90 percent of the meth found in the United States, and 80 percent of precursor chemicals used in Mexican meth come from China. 15 In the 2014 INCSR, the U.S. Department of State indicated criminal syndicates in China were redirecting legal chemical shipments for illegal use, with “most precursor chemicals seized in Mexico and Central America destined for illegal production of meth ... legally exported from China and diverted en route.” 16 These claims were restated in the 2016 INCSR, which indicated China remains one of the world’s top producers and exporters of precursor chemicals. 17 Undetected illegal precursor chemicals shipped from China are made into meth and transported to the U.S.-Mexico border, crossing over the southern border of the United States into southwestern states—Texas, Arizona, and California—before being shipped across the country. 18

Despite introducing more stringent regulations on precursor chemicals, Mexico remains a chief transit point for illicit Chinese chemicals. 19 During an interview with the Hong Kong-based newspaper South China Morning Post in 2014, Jorge Guajardo, Mexico’s ambassador to China from 2007 to 2013, described Chinese meth precursor exports to Mexico as “the number one issue [he] had to address” in his time as ambassador. 20 In 2008, new regulations went into effect limiting sales of cold medicines and other legal products containing ephedrine and pseudoephedrine in Mexico. 21 Despite these precautions, precursor flows into Mexico continue to increase. 22 Between 2009 and 2011, the volume of meth and precursor chemical seizures in Mexico increased 1,000 percent. 23 Most of the precursor chemicals are suspected to have originated in China. 24 Mexican authorities seized a record 900 tons of precursor chemicals from China in just six weeks in 2012. 25

With Mexican and U.S. officials cracking down on precursor imports, Chinese chemical exporters are taking additional steps to ensure precursor shipments arrive undetected. Chinese triads—organized crime syndicates operating throughout Asia and beyond—have increased their cooperation with Mexican criminal organizations and are now the main suppliers of precursor chemicals to Mexico. 26 The triads work in conjunction with Mexican drug cartels, including the Sinaloa and Knights Templar cartels, to produce and transport chemicals and bypass laws and import regulations. 27 Chinese drug traffickers also undermine Mexico’s anti-precursor regulations by transporting chemicals into Central American countries, which are vulnerable to narcotics trafficking due to their remoteness, limited infrastructure, lack of government presence, and weak law enforcement institutions (see Figure 2). 28 James Bosworth, CEO of the strategic advisory firm Southern Pulse, explained in an interview with Commission staff, “On top of direct covert trafficking into Mexico’s Pacific ports, precursor materials from China enter ports in countries like Guatemala, Honduras, El Salvador, and Venezuela before being transported into Mexico by land and sea routes, making them difficult to detect.” 29

China’s Meth Problem

While precursor exports drive a significant portion of China’s meth-making market, domestic meth consumption in China has also increased dramatically over the past decade, despite efforts to crack down on producers and users. 30 Ten years ago, China’s population of known drug abusers totaled around one million people, with 86 percent of them taking opiates like heroin and opium, while only 14 percent abused meth. 31 A report from China’s National Narcotics Control Commission in March 2015 revealed the number of known drug users has tripled since 2005, reaching 2.95 million. 32 Liu Yuejin, the director of the Narcotics Control Bureau at the Ministry of Public Security, has indicated the actual number of drug addicts in China is “estimated at 13 million ... and about half are suspected of taking methamphetamine.” 33 While the data on drug users in China remain difficult to verify, drug seizure statistics show meth use becoming more prevalent in the last 15 years. In 2001, opiate seizures outpaced all other drug seizures in China, with authorities seizing 16,000 kg of opiate drugs compared to 4,820 kg of meth. 34 By 2014, however, meth seizures had increased by 437 percent, with nearly 26,000 kg seized, while heroin seizures had declined by 42 percent to 9,300 kg (see Figure 3). 35

Numerous drug busts have occurred in China in the last few years, particularly in coastal provinces. In February 2015, for instance, 2.2 kg of meth were seized and 28 people were arrested for meth production in Guangdong Province. 36 In January 2016, 150 kg of meth and one ton of precursor materials were seized in the city of Panyu, Guangdong. 37 China’s largest meth seizure occurred in December 2013 when 3,000 heavily armed police raided Boshe, a small village located on China’s southeast coast in Guangdong Province. 38 The town had become one of China’s major producers of precursor chemicals and an international drug trafficking channel due to its location and developed sea and land transport infrastructure. 39 During the bust, police reported closing 77 separate meth labs, seizing more than three tons of meth along with 23 tons of precursor chemicals and arresting 182 people. 40 In all, nearly 20 percent of the villagers living in Boshe had been involved in the drug trade in some way, earning as much as ten times more through meth production than they could have as standard fishing or orchard workers. 41

China has attempted to stem domestic meth production by introducing new drug regulations, more stringently enforcing existing drug laws, and cooperating with international drug combatting efforts. Amendments to China’s Criminal Law in 2015, for instance, set explicit punishments for illegally producing and distributing precursor chemicals, including providing new criminal penalties for illegal drug activity. * 42 China also rolled out a new electronic precursor control information system aimed at facilitating applications for chemical licenses and enhancing verification procedures for precursor operators and transactions involving precursor chemicals. 43 Most recently, in October 2015 China added 116 synthetic chemicals to the list of controlled chemical substances, including components necessary for the manufacture of synthetic ephedrine and pseudoephedrine. 44 While it is difficult to measure the impact these laws have on drug use and production in the short term, they signal Beijing’s awareness of the country’s growing drug problem and a willingness to address it. 45

Police in China have also begun cracking down on the sale and use of meth, with the number of drug-related trials increasing by roughly 80 percent from 2007 to 2011. 46 In 2014, law enforcement officials investigated 145,900 drug trafficking cases resulting in 168,900 drug-related arrests—a 27 percent increase since 2012—and seized 25.9 tons of meth, up 60 percent from 2012. 47 In addition, police seized nearly 4,000 tons of precursor chemicals in 2014, a record 350 percent increase from 2010 levels. 48 In 2015, over one million drug users were arrested in China—a 20 percent increase year-on-year—including 776,000 meth users. 49 These efforts have deterred recreational drug activity in the country, yet large-scale meth production continues to increase. 50

Along with efforts to combat domestic drug use, China has enhanced its cooperation with international counternarcotic organizations. China is an original signatory to the 1988 UN Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances, which provides measures against drug trafficking and the diversion of precursor chemicals. 51 China also maintains bilateral counternarcotic agreements with the UN Office on Drugs and Crime (UNODC), as well as memoranda of understanding with Burma (Myanmar), Cambodia, Laos, Thailand, and Vietnam on narcotic drug control. 52 Through these agreements, China has sought to combat drug crimes more actively, attending various high-level dialogues on drug control and signing on to joint projects cracking down on transnational narcotics-related crimes. 53 In addition, China participates in a variety of international drug conferences and bilateral meetings, including the annual International Drug Enforcement Conference hosted by the DEA. 54 China has also increased its work with multilateral partners through organizations such as the UNODC and the UN Commission on Narcotic Drugs (UNCND)—the UN’s primary narcotic drug policy-making body—to control for new chemicals like the 116 illegal synthetic compounds banned in October 2015. 55 However, controlling these 116 synthetic chemicals is unlikely to significantly reduce China’s precursor production, with new synthetic chemicals quickly replacing banned ones in circulation. 56

Scope of China’s Pharmaceutical and Chemical Production

Despite efforts to crack down on chemical production and distribution, China’s drug problem continues unabated in part because the country’s robust chemical and pharmaceutical industries are producing vast legal quantities of meth precursor chemicals. 57 Throughout the last decade, the Chinese government has prioritized pharmaceutical production as a “high value-added industry,” providing export tax rebates to producers of pharmaceutical ingredients to boost exports. 58 Today, China’s pharmaceutical market—which consists of more than 5,000 pharmaceutical companies producing legal synthetic chemicals and drugs—is the second largest in the world with a revenue of $105 billion in 2014, although it trails far behind the United States’ $380 billion pharmaceutical industry. 59 China’s market is still growing rapidly, with revenues increasing 15 percent on an annualized basis since 2010 and expected revenues of $200 billion by 2020. 60

Unlike the United States, which produces costly, high-value pharmaceuticals, China’s pharmaceutical industry relies on mass production and export of inexpensive generic drugs and APIs. 61 This explains why China became the largest manufacturer of pharmaceutical ingredients in 2012 (producing around 800,000 tons of APIs) yet still took in revenues equal only to 28 percent of U.S. pharmaceutical industry revenue. 62 Together with the country’s large domestic consumer market, the scale of API production in China has facilitated economies of scale that lower costs for chemical production. 63 As a result, China has become the leading global exporter of APIs, with other countries importing pharmaceutical ingredients from China to lower production costs for drugs and medicines. 64 A 2010 study of pharmaceutical executives by the consulting firm Axendia, for example, found 70 percent of respondents cited China as their top country source for pharmaceutical ingredients. 65 Although these shipments are legal, APIs and other noncontrolled pharmaceutical products can still be used for drug and precursor drug production, particularly in cases where the APIs are counterfeit or adulterated during production to make cheaper and more potent products. * 66

In addition, China’s numerous nonpharmaceutical chemical companies legally produce massive quantities of meth precursor chemicals every day. 67 China surpassed the United States as the world’s largest chemical market in 2009, and by 2014 global chemical shipments from China reached $1.8 billion, or 34 percent of global shipments, compared to a 15 percent share for U.S. chemical shipments. 68 The U.S. Department of State estimates that nationwide, China has more than 160,000 chemical companies operating legally and illegally, with facilities manufacturing tons of precursor chemicals every week. 69 As a result, China has become a leading producer and exporter of precursor chemicals: 70 in 2014 (the last year chemical export data are available) China was the world’s sixth-largest exporter of ephedrine (2,100 kg) and fifth-largest exporter of pseudoephedrine (65,678 kg). * 71

Regulations Governing Chemical Production in China

In many cases, the precursor chemicals used to produce meth are diverted from legitimate pharmaceutical uses. 72 Preventing the theft and diversion of precursor chemicals necessitates coordination and cooperation among law enforcement, chemical producers, and pharmaceutical retailers. 73 However, China’s vast chemical and pharmaceutical industries are weakly regulated and poorly monitored, making it easy for drug traffickers to divert chemicals with legitimate uses in medicine, fertilizer, and pesticides to meth and other synthetic drug production. 74 China controls more than 25 known precursor chemicals—including ephedrine and pseudoephedrine—which should subject these chemicals to strict production, sale, and export licensing requirements (for a full list of Chinese controlled precursor chemicals, see Appendix II, “Controlled Precursor Chemicals in China”). 75 In an interview with Commission staff, however, officials at the U.S. Food and Drug Administration described the complexity of the oversight of chemicals in China at the national, provincial, municipal, and local levels, and expressed concern over the difficulty of enforcing regulations of chemicals when responsibility falls under numerous jurisdictions. 76

In addition, regulatory loopholes and insufficient enforcement protocols allow criminals to produce unregulated precursors and divert APIs and other chemicals with legitimate uses into the production of meth and other new and dangerous synthetic drugs. 77

China’s fragmented governing structure has contributed to administrative problems controlling chemical production, with conflicts of interest between regulatory agencies frequently contributing to regulatory failure. 78 Numerous agencies are involved in regulating chemical companies, with bureaucratic infighting preventing the government from carrying out precise and effective counternarcotic operations. 79 China’s Food and Drug Administration (CFDA), for example, is responsible for drafting laws, enforcing regulations, and conducting investigations for all food safety and drug issues. 80 Additionally, a State Council Leading Group on Product Quality and Food Safety coordinates government agencies in addressing major issues related to product quality and drug safety, and the National Narcotics Control Commission coordinates with relevant Chinese departments and international agencies to meet China’s obligations under international drug control conventions. 81 An Anti-Smuggling Bureau within the General Administration of Customs is responsible for the enforcement of China’s drug control laws at seaports, airports, and land border checkpoints; the Ministry of Chemical Industry, Ministry of Agriculture, and Ministry of Commerce—along with the General Administration of Quality Supervision, Inspection, and Quarantine—play roles in the inspection, licensing, and export of pharmaceutical products, including precursor chemicals and APIs. 82

Deficient local drug inspection and enforcement capabilities are another limitation of China’s chemical regulations. 83 China is home to approximately 400,000 retail pharmacy shops legally selling products containing ephedrine and pseudoephedrine and other precursor chemicals, in addition to the 160,000 precursor production plants and 5,000 pharmaceutical companies. 84 Because regulators are not able to adequately inspect all chemical production and distribution facilities, precursor chemical producers easily avoid detection by migrating to jurisdictions with less vigilant drug enforcement. 85 Chinese law enforcement personnel are mainly concentrated in urban centers, leading to increased drug activity in rural areas and poorer communities. 86 Meanwhile, online API and precursor sales remain extremely covert in China and are difficult for law enforcement authorities to identify, allowing drug producers to collect payments and deliver chemicals without detection. 87 In a 2015 New York Times investigation into China’s unbridled online drug market, a UN official explained that China has “an enormous chemical industry and ... doesn’t have the capacity to monitor and control it.” 88

China’s regulations governing nonpharmaceutical chemical production are also limited and easy to bypass. 89 In 2011, the CFDA published new drug manufacturing practices, which were viewed as a significant step toward improving inspection and oversight procedures. 90 However, due to a regulatory loophole that left Chinese chemical companies out of the CFDA’s jurisdiction, Chinese chemical production facilities—even those making pharmaceutical components and APIs—were registered as nonpharmaceutical companies with the state, leaving them in a gray area of regulation free from inspection requirements and other certification systems. 91 In an interview in 2007, Yan Jiangying, the former deputy director of policy and regulation at the CFDA, revealed the CFDA had “never investigated a chemical company,” because “we don’t have jurisdiction [to do so].” 92 The loophole was not closed until 2014, when China’s State Administration of Work Safety implemented new regulations on the management of precursor chemicals to strengthen oversight on nonpharmaceutical businesses, including enforcing stricter licensing requirements. 93 It is unclear, however, if the new regulations have sufficiently addressed the issue.

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* Export figures do not include illicit trafficking and production of ephedrine and pseudoephedrine. United States Department of State, 2014 International Narcotics Control Strategy Report (INCSR), March 2014. xttp://www.state.gov/j/inl/rls/nrcrpt/2014/vol1/223176.htm.

In addition, inadequate regulations on chemical companies have led to a large number of unlicensed chemical companies operating in China. 94 Many of China’s chemical production facilities are described as “semi-legitimate” producers, which are allowed to make chemicals but unlicensed to sell them to pharmaceutical companies. 95 Instead, semi-legitimate chemical companies churn out massive quantities of product to sell in bulk to licensed chemicals manufacturers as compounds for pharmaceuticals. 96 The operations of semi-legitimate chemical companies are difficult to investigate because they sell to other businesses—many of which operate with little-to-no government oversight and regulation—and not to the general public. 97 Through these unlicensed chemical companies, drug traffickers can easily gain access to precursor chemicals. 98

Pharmaceutical companies also take advantage of the lack of oversight on chemical companies, creating “show and shadow factories” whereby the company registered with the Chinese government and inspected by the CFDA is not where the chemicals are produced. 99 To get around CFDA regulations, pharmaceutical firms will buy a token amount of chemicals from certified suppliers to pass inspection, while using unlicensed facilities to produce a
majority of their products, including precursor chemicals. 100 Thus, not only are pharmaceutical ingredients manufactured by China’s chemical companies not really inspected or certified for pharmaceutical use, but also their production of precursor chemicals far exceeds limits imposed by regulators. 101 In 2007, Wang Siqing, the managing director of a pharmaceutical company in China, estimated uncertified chemical companies make half the active pharmaceutical ingredients sold in China, with most exports from unregulated companies going to Africa or South America. 102 Although China has begun more stringently enforcing regulations governing pharmaceutical production in recent years, FDA officials still “routinely come across shadow facilities” when conducting inspections of Chinese pharmaceutical companies. 103

Along with shortfalls in Chinese regulations governing precursor production, anecdotal evidence suggests corrupt government officials actively undermine chemical production regulations. 115 A 2002 report by the Washington Post revealed that Chinese military leaders were participating in counterfeit and illegal chemical trade, with military trucks being used to transport pharmaceuticals for unlicensed chemical production. 116 This behavior was tolerated by officials, with corrupt politicians paid off to not inspect manufacturing facilities or conduct drug quality assessments. 117 As recently as 2008, local government officials in Guangdong Province, a meth-making hub in China, were caught encouraging farmers to illegally grow plants that produce a natural source of ephedrine for meth production. 118 In the last few years, however, Beijing has begun cracking down on local government corruption, expelling 41 officials from Yunnan Province for drug use in 2014. 119 Still, officials are susceptible to bribery from drug producers, particularly in localities where regulators are underpaid and overloaded with applications. 120

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Beyond Meth: China’s Fentanyl Production

In addition to producing meth precursor chemicals, China exports other synthetic drug precursors, including compounds necessary for the manufacture of fentanyl and fentanyl-like substances. Fentanyl, a Schedule II drug, is a powerful synthetic opiate painkiller similar to morphine but 100 times more potent. 104 U.S. health and law enforcement officials have seen a recent spike in fentanyl-related deaths, with a recent report from the Centers for Disease Control and Prevention indicating deaths from overdoses of illicitly manufactured fentanyl and synthetic opioid pain relievers increased 80 percent year-on-year in 2014. 105 According to drug investigators, Chinese suppliers are providing both raw fentanyl and the machinery necessary for fentanyl production. 106 Like meth, fentanyl and fentanyl-like products are made in Mexico from Chinese chemicals before being transported to the United States. 107

Fentanyl and many of its analogs are now controlled in China as part of the 116 new banned chemicals announced in October 2015. 108 Recently, Chinese manufacturers started producing and openly selling a new form of the drug in China, called furanyl fentanyl. 109 Because of its modified chemical structure, the substance is not currently controlled in the United States or China. 110 The DEA is working to add furanyl fentanyl to the U.S. list of controlled substances and pressuring China to include the drug in its list of banned synthetic chemicals. 111 Counternarcotic experts warn banning the chemical is not enough, however, and will lead to the creation of a new synthetic substance, much as banning fentanyl resulted in the spread of furanyl fentanyl. 112

Legislation has already been passed at the state level to strengthen U.S. anti-trafficking laws as they relate to fentanyl. In February 2016, Massachusetts enacted a law making the trafficking of fentanyl a crime and increasing the penalty for fentanyl possession and distribution from ten to 20 years. 113 Although the trafficking of other drugs, including heroin, marijuana, and cocaine, was already criminalized, the state did not have similar laws for fentanyl. 114

U.S. Efforts to Address Precursor Chemical Flows from China

Although the majority of meth sold in the United States is made with precursor chemicals originating in China, these precursors do not enter the United States directly. Rather, they are transported via a network of land and sea routes to Central America. 121 This considerably complicates U.S. counternarcotic efforts. In many cases, precursor chemicals are shipped openly and legally because they are not controlled in China or in the destination country. 122 Therefore, precursor chemical flows cannot be reduced through U.S.-China bilateral efforts alone, but also require cooperation with Central American countries. 123

To reduce precursor chemical flows, the United States and the international community at large have intensified counternarcotic cooperation efforts with China. The U.S.-China Joint Liaison Group, for instance, which convened its 14th annual meeting in October 2015, seeks to address global law enforcement concerns shared by the United States and China, including controlling precursor chemical flows and cooperating on trends in drug abuse and trafficking. 124 The DEA and the Narcotics Control Bureau of China are also parties to the Bilateral Drug Intelligence Working Group, which brings legal and law enforcement experts together to share drug trafficking information and discuss new avenues for antidrug cooperation. 125 In addition, the U.S. Pacific Command’s (PACOM) Joint Interagency Task Force-West (JIATFW) works with Department of Defense counternarcotic authorities to open new avenues of cooperation with Chinese officials, providing training and other support to combat drug trafficking. 126 Admiral Harry Harris, the commander of PACOM, said JIATFW’s efforts “show promise in improving communication, cooperation, and information sharing on significant criminal enterprises operating in the U.S. and China.” 127

International tracking systems like the Pre-Export Notification (PEN) system and Precursors Incident Communication System (PICS) can also be used to identify suspicious transactions in international trade. 128 The PEN system was created under the 1988 UN Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances, and is used by 150 UN member states and territories—including China—to provide clearance for chemical shipments and acknowledge receipt of precursor chemical exports. 129 PICS is an online tool developed in 2012 by the U.S. Bureau of International Narcotics and Law Enforcement Affairs (INL) to enhance real-time communication and information sharing between national authorities on precursor incidents. 130 These communication tools have fostered coordination among competent national authorities, with PICS, for example, used to share intelligence on more than 800 instances of chemical trafficking since 2012 (for a full list of UN controlled chemicals, see Appendix III, “Controlled Chemicals under 1988 UN Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances”). * 131

Enhanced chemical regulations and streamlined emergency scheduling † protocols enable U.S. law enforcement officials to limit shipments of new or modified chemicals. In May 2016, the president signed the Transnational Drug Trafficking Act into law, lowering the threshold for prosecuting extraterritorial drug traffickers to include individuals with “reasonable cause to believe” that their illegal drugs will be trafficked into the United States. 132

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*
* As of November 1, 2014, China had accessed the PICS database over 50 times. UN International Narcotics Control Board, “Precursors and Chemicals Frequently Used in the Illicit Manufacture of Narcotic Drugs and Psychotropic Substances,” March 2015, 15.
† Emergency scheduling introduces temporary restrictions on a chemical while a final decision is made on whether to permanently control the substance. Jonathan P. Caulkins and Carolyn Coulson, “To Schedule or Not to Schedule: How Well Do We Decide?” Journal of Global Drug Policy and Practice 205:20 (December 2010): 11.

Additionally, the Synthetic Drug Abuse Prevention Act (signed into law in 2012) banned more than 20 chemical compounds used in synthetic drugs, doubled the review period for emergency scheduled substances from 18 to 36 months, and expanded the DEA’s emergency scheduling authority to allow the DEA to more quickly ban new chemicals. 133 Between May 2012 and February 2014, the DEA emergency scheduled more than 20 chemicals deemed to present an imminent hazard to public safety and significantly reduced the number of harmful chemicals in the United States. 134 In its 2012 annual report, the UN International Narcotics Control Board praised international efforts to streamline emergency scheduling procedures, stating that they have been “highly effective in ensuring that the public is not unnecessarily put at risk before a comprehensive evaluation of [a] substance can be undertaken by national authorities.” 135

The United States also supports efforts to develop and strengthen international precursor laws and regulations in compliance with international drug control treaties. The INL, for instance, manages and funds international counternarcotic training programs, which focus on increasing cooperation and improving the technical skills of foreign drug law enforcement personnel. 136 U.S. counternarcotic efforts consist of both general law enforcement training and specialized training for mid-level managers in police and other law enforcement agencies around the globe. 137 However, the INL does not have a representative in Beijing and does not provide funding for counternarcotic efforts in China. 138 Instead, the Department of State and DEA combat Chinese drug trafficking organizations by providing investigative assistance to foreign governments—particularly in Central America—and helping to develop more effective international drug control laws and regulations. 139

While the INL has no direct funding projects in China or East Asia to reduce drug-related activity, the United States has funded programs to cut off chemical flows into Central America, including dedicating $1.15 billion between 2008 and 2015 to the Central America Regional Security Initiative (CARSI). 140 Nearly 66 percent of CARSI’s funding was given to the International Narcotics Control and Law Enforcement foreign aid account, helping Central American governments build law enforcement institutions to counter transnational crime—including narcotics—and create transparent and accountable public institutions. 141 The DEA’s Sensitive Investigative Unit (SIU), authorized by Congress in fiscal year (FY) 1997, also conducts field operations in Central American countries designated by Congress, identifying and training DEA foreign counterparts in counternarcotic investigations. 142 According to the United States Department of Justice, the SIU program has “unquestionably enhanced DEA’s ability to fight drug trafficking on a global scale.” 143 Despite increasing levels of trafficking activity in China, Congress has not designated China as a specific SIU location, and thus there are no units currently operating in the country. 144

Limitations of Counternarcotic Regulations

U.S. efforts to reduce international narcotic and drug trafficking remain insufficiently equipped to reduce shipments of precursor chemicals from China. The numerous ways precursor exports can be hidden include:

Mislabeling: Mislabeling shipments of precursor chemicals is one way Chinese drug traffickers avoid detection by U.S. and foreign authorities. 145 According to members of the team at JIATFW, “As
international authorities have intensified efforts to identify and seize illegal precursor shipments, drug traffickers have begun mislabeling chemical shipments with greater frequency. As mislabeling increases,
so do the challenges for law enforcement and customs officers in identifying these shipments.” 146

Modifying Chemicals:  Precursors can also be chemically modified, making them technically legal and permissible to export. 147 These modified chemicals contain compounds similar to banned precursors and
are designed to mimic their use, but are not included on the UN or U.S. lists of banned chemicals. 148 Because
PICS and the PEN system can only identify chemicals controlled by the UN and United States, new or
modified chemicals are not flagged. 149 In addition, DEA officials told Commission staff that hundreds of
different chemical combinations can be used to produce drug precursor chemicals, making it difficult for
regulatory authorities to keep up. 150

Shipping Pre-Precursor Chemicals:  As precursor chemicals have become more difficult to ship undetected, Chinese drug traffickers have begun transporting pre-precursors, or the chemicals used to create
precursors. 151 By shipping noncontrolled pre-precursor chemicals—including APAAN (alpha-phenylacetoacetonitrile), benzaldehyde, and nitroethane, among others—traffickers are able to avoid detection. 152 Like modified chemicals, many pre-precursors are legal, and so are not flagged by PICS or the PEN system. 153

Insufficient Partner Country Counternarcotic Capabilities: Many Central American countries still lack the institutional and regulatory capabilities to identify and seize illegal precursor chemical shipments. 154 Chinese drug traffickers take advantage of these weaknesses in global counternarcotic operations, sending precursor chemicals to countries where the chances of detection and seizure are lower. 155 When precursors are detected, Central American governments often lack proper means for storage and disposal, instead holding the chemicals in ports and warehouses that can result in environmental degradation. 156

Illegal Activity: Because they are illicit, drug shipments facilitated by criminal organizations limit the effectiveness of the PICS and the PEN system, customs and port authority inspections, and other regulations governing precursor flows. Transnational criminal organization operatives typically use large, illegally operated boats to smuggle precursor chemicals from China to ports in Central America and Mexico, where organized crime groups pick up the chemicals and transport them in SUVs and trucks to meth labs. 157 These operations—commonly carried out by Chinese triads and Central American drug cartels—circumvent the counternarcotic regime currently in place. 158

Considerations for Congress

Although chemical production is difficult to measure in China’s opaque pharmaceutical and chemical industries, China is clearly one of the world’s largest manufacturers of precursor chemicals. 159 China has made efforts to reduce its domestic meth production and curb the export of precursor chemicals, yet the country’s vast pharmaceutical and chemical industries remain largely unregulated. As a result, meth precursor chemical flows—along with other dangerous synthetic drugs—from China into the Western Hemisphere continue to increase, contributing to a growing drug problem in the United States.

The onus to reduce China’s meth precursor chemical production lies largely on Beijing. The increasing frequency of drug raids in meth-producing towns like Boshe, along with the implementation of new antinarcotic regulations, indicate the Chinese government is aware of this growing drug problem and willing to address the issue. To reduce the prevalence of meth—both in China and around the world—Chinese leaders should continue to address shortfalls in existing chemical regulations and implement new requirements for chemical production.

The United States and other foreign nations also bear responsibility for enhancing international regulations governing chemical shipments and drug trafficking. Countries have attempted to reduce precursor imports through stricter chemical regulations, with the U.S. and Mexican governments both restricting sales of products containing precursor chemicals. Drug producers have several methods for avoiding detection by local and international authorities and circumventing Chinese and international antidrug regulations, including mislabeling chemical shipments, modifying illegal chemicals, and shipping legal pre-precursor chemicals.

To reduce precursor chemical flows from China into the Western Hemisphere, Congress should consider the following questions:

How can Congress encourage China to improve its chemical production regulations?

Congress should encourage future administrations to work with Beijing to centralize its drug authorities and coordinate more closely with the DEA and U.S. FDA. Giving one agency like the CFDA sole authority
over pharmaceutical and chemical production in China would formalize inspection practices, allow for better distribution of counternarcotic resources, and simplify coordination and communication efforts
between Chinese regulators and their counterparts in the United States. Along with encouraging an increased role for the CFDA, establishing more frequent communication between U.S. and Chinese drug
regulators could increase awareness of suspected drug shipments, leading to more seizures and reduced precursor flows.

Congress should encourage future administrations to pressure Beijing to revise its laws governing chemical exports. Currently, Chinese law enforcement lacks the authority to crack down on meth precursor
production because many of the chemicals are not controlled in China. To enhance Chinese law enforcement’s ability to enforce precursor restrictions, Beijing should adopt new regulations making it
illegal to knowingly ship a substance that is illegal in the destination country. Additionally, Beijing should add additional meth precursor chemicals to its list of controlled substances.

How can global communication networks be enhanced?

Congress should recommend that the U.S. Department of State’s Bureau of International Narcotics and Law Enforcement Affairs send a team to Beijing to cooperate directly with Chinese law enforcement on
counternarcotic issues. Increased communication with antidrug counterparts in Central America and Asia—with the United States acting as a facilitator for these discussions—could significantly reduce drug
traffickers’ ability to circumvent regulations and facilitate illegal precursor flows.

How can capabilities for tracking and destroying Chinese chemicals be improved?

The United States should designate China as a SIU location. By adding a SIU unit in China, the DEA could better establish an effective and trustworthy counternarcotic system in China. To accommodate this
expansion, Congress should consider increasing funding for the program.

How should Congress recommend China reform laws governing precursor chemical production?

Congress should encourage future administrations to pressure Beijing to revise its laws governing chemical exports. Currently, Chinese law enforcement lacks the authority to crack down on meth precursor
production because many of the chemicals are not controlled in China. To enhance Chinese law enforcement’s ability to enforce precursor restrictions, Beijing should adopt new regulations making it
illegal to knowingly ship a substance that is illegal in the destination country. Additionally, Beijing should add additional meth precursor chemicals to its list of controlled substances.

How can global communication networks be enhanced?

Congress should recommend that the U.S. Department of State’s Bureau of International Narcotics and Law Enforcement Affairs send a team to Beijing to cooperate directly with Chinese law enforcement on
counternarcotic issues. Increased communication with antidrug counterparts in Central America and Asia—with the United States acting as a facilitator for these discussions—could significantly reduce drug
traffickers’ ability to circumvent regulations and facilitate illegal precursor flows.

How can capabilities for tracking and destroying Chinese chemicals be improved?

The United States should designate China as a SIU location. By adding a SIU unit in China, the DEA could better establish an effective and trustworthy counternarcotic system in China. To accommodate this
expansion, Congress should consider increasing funding for the program.

Appendix II: Controlled Precursor Chemicals in China

Category 1 - High Risk Substances

01. 1-phenyl-2-propane, CAS 103-79-7
02. 3,4-Methylenedioxyphenyl-2-propanone, CAS4676-39-5
03. Piperonal, CAS 120-57-0
04. Safrole, CAS 94-59-7
05. Sassafras oil
06. Iso-safrole, CAS 120-58-1
07. N-Acetylanthranilic acid, CAS 89-52-1
08. O-amino benzoic acid, CAS 118-92-3
09. Ergotic acid, CAS 82-58-6
10. Ergotamine, CAS 113-15-5
11. Ergobasine, CAS 60-79-712
12. Ephedrine, pseudoephedrine, mesoephedrine, phenylpropanolamine, methylephedrine, ephedrine extractum, ephedrine extractum power, and other ephedrine substances
13. Hydroxylimine, CAS 90717-16-1 and its salts (added in 2008)
14. 2-Chlorophenyl cyclopentyl ketone, CAS 6740-85-8 (added in 2012)
15. 1-Phenyl-2-Bromo-1-Propanol, CAS 2114-00-3 (added in 2014)
16. 3-oxo-2-phenylbutyronitrile, CAS 4468-48-8 (added in 2014)

Category 2 - Precursors

1. Phenylacetic acid, CAS 103-82-2
2. Acetic anhydride, CAS 108-24-7
3. Chloroform, CAS 67-66-3
4. Aether, CAS 60-29-7
5. Piperidine, CAS 110-89-4

Category 3 - Other Raw Materials

1. Toluene, CAS 108-88-3
2. Acetone, CAS 67-64-1
3. Methyl ether ketone, CAS 78-93-3
4. Potassium permanganate, CAS 7722-64-7
5. Sulphuric acid, CAS 7664-93-9
6. Hydrochloric acid, CAS 7647-01-0

Source: ChemSafetyPRO, “Management of Drug Precursor Chemicals in China.”
xttp://www.chemsafetypro.com/Topics/China/Drug_Precursor_Chemicals.html.

159 references. See attached PDF report for the refs.
2
News / Report: Fentanyl - China’s Deadly Export to the United States
« Last post by Happless on Today at 10:57:53 AM »
This is a very enlightening report on the Chinese chemical labs and their role in supplying illicit fentanyl and fentanyl analog powders to North America, and why US customs has trouble stopping the flow. This report was produced by a policy analyst for the US-China Economic and Security Review Commission.

Quote from: Wikpedia
The United States-China Economic and Security Review Commission is a congressional commission of the United States government. Created through a congressional mandate in October 2000, it is responsible for monitoring and investigating national security and trade issues between the United States and People's Republic of China. The Commission holds regular hearings and roundtables, produces an annual report on its findings, and provides recommendations to Congress on legislative actions related to China.

Fentanyl: China’s Deadly Export to the United States

February 1, 2017

Author: Sean O’Connor, Policy Analyst, Economics and Trade @ U.S.-China Economic and Security Review Commission

Acknowledgments: The author thanks Bart Carfagno, Research Fellow, Economics and Trade, for his research assistance. The author also thanks officials at the U.S. Drug Enforcement Administration and U.S. Department of Justice for their helpful insights. Their assistance does not imply any endorsement of this report’s contents, and any errors should be attributed solely to the author.

Executive Summary

Chemical flows from China have helped fuel a fentanyl crisis in the United States, with significant increases in U.S. opioid overdoses, deaths, and addiction rates occurring over the last several years. Unlike previous opioid epidemics, including a temporary spike in U.S. fentanyl use in 2006 that was traced to a single clandestine lab in Mexico, fentanyl sold in the United States is now being produced by individual distributors across the country. The diffused nature of fentanyl distribution and the drug’s high potency have complicated U.S. counternarcotic efforts and necessitated new policies aimed at reducing flows of fentanyl and other synthetic opiates to the United States. The U.S. Drug Enforcement Administration (DEA) is the federal government’s primary counternarcotic authority, working with state and local law enforcement to regulate and enforce controls on illicit drugs and chemicals. According to U.S. law enforcement and drug investigators, China is the primary source of fentanyl in the United States. Along with shipments sent directly to the United States, fentanyl is shipped from China to Mexico and, to a lesser degree, Canada, before being trafficked across the U.S. border. In response, the U.S. and Chinese governments have taken steps to increase counternarcotic cooperation and strengthen regulations governing chemical flows. However, these efforts have not adequately adapted to drug exporters’ increasingly sophisticated production and distribution methods.

China is a global source of fentanyl and other illicit substances because the country’s vast chemical and pharmaceutical industries are weakly regulated and poorly monitored. Chinese law enforcement officials have struggled to adequately regulate the thousands of chemical and pharmaceutical facilities operating legally and illegally in the country, leading to increased production and export of illicit chemicals and drugs. Chinese chemical exporters utilize various methods to covertly ship drugs to the Western hemisphere, including sending illicit materials through a chain of forwarding systems, mislabeling narcotic shipments, and modifying chemicals so they are not controlled in the United States. To reduce flows of fentanyl and fentanyl-like substances to the United States, U.S. regulators should reexamine policies and procedures for banning and controlling dangerous chemicals and work with their Chinese counterparts to improve regulations governing chemical exports.

A Dangerous and Increasingly Abundant Drug

A cheap, synthetically produced opioid known as fentanyl has spawned a deadly drug crisis in the United States. 1 Fentanyl, a powerful synthetic painkiller about 50 times more potent than heroin and 100 times stronger than morphine, is a Schedule II drug—meaning it is legally available only through a nonrefillable prescription. 2 After being introduced more than 50 years ago as an intravenous anesthetic, fentanyl was approved for treating severe pain (typically for advanced cancer patients) in the early 1990s and has since become a more commonly prescribed painkiller, with U.S. doctors writing 6.65 million fentanyl prescriptions in 2014. 3 The drug is commonly prescribed in the form of transdermal patches or lozenges, but it can be diverted from its medical applications and misused by removing the gel contents from patches and injecting or ingesting the drug, or compressing it into pill form. 4 Recreational use of illicitly obtained fentanyl and other new psychoactive substances (NPS) has spread across the United States, with the DEA issuing nationwide health and public safety alerts in March 2015 and June 2016 about the dangers of fentanyl. 5 In part, fentanyl is an attractive alternative to other opioids like heroin and oxycodone because it is more potent, with users typically requiring less than a milligram of the drug for a single use. 6 In fact, fentanyl is so potent that touching or inhaling just two milligrams (or about two grains of salt) can be lethal, presenting a threat not just to drug users, but also to law enforcement personnel investigating the scene of a fentanyl overdose or production locations. 7 Fentanyl is also appealing to drug users because it is inexpensive; producing 25 grams of finished fentanyl costs about $810. 8 The combination of the drug’s potency and affordability has made fentanyl an increasingly common drug in the United States, often mixed with heroin or cocaine—either intentionally or without the user’s knowledge—to increase its euphoric effects. 9

U.S. health and law enforcement officials have seen a recent spike in fentanyl-related abuse and overdoses. 10 A January 2016 report from the Centers for Disease Control and Prevention indicated 5,544 deaths from overdoses of illicitly manufactured synthetic opioids occurred in the United States in 2014, a 79 percent increase year-on-year. 11 The death rate from synthetic opioids, including fentanyl, increased by another 72.2 percent year-on-year in 2015. 12

A substantial portion of the increase is attributable to the increased availability of illicit fentanyl, which the U.S. Customs and Border Protection reports is the most frequently seized synthetic opioid. 13 In 2015, U.S. law enforcement seized a record amount (approximately 368 pounds) of illicit fentanyl. 14 As seen in Figure 1, there was widespread fentanyl use nationwide in 2015, with laboratories in every state finding fentanyl in forensic tests, according to the National Forensic Laboratory Information System (NFLIS). 15 Increased fentanyl use is most common in areas where white powder heroin is prevalent—particularly across the eastern United States—because fentanyl is often mixed with or disguised as white powder heroin. 16 Although more recent data on fentanyl use are not yet available, it is clear the fentanyl crisis has continued to worsen. Between January and March 2016, counterfeit pills containing fentanyl led to nine deaths in Pinellas County, Florida, and in March and April 2016 authorities recorded 52 overdoses and ten deaths due to fentanyl in Sacramento, California. 17 In November 2016, Virginia Governor Terry McAuliffe announced that the state’s opioid addiction crisis had become a public health emergency, with the number of fatal opioid overdoses expected to rise 77 percent by the end of 2016 compared to 2011. 18 Fentanyl also garnered national media attention in June 2016 when the Midwest Medical Examiner’s Office concluded U.S. singer-songwriter Prince died from an accidental fentanyl overdose. 19

Figure 1: Fentanyl Exhibits Tested, 2015, and Wholesale Seizures, 2013–2015 SEE ATTACHED PDF

U.S. Drug Policy: Regulations and Enforcement

Several U.S. federal agencies share responsibility for regulating dangerous narcotics, and work with state and local law enforcement agencies to detect and prevent drug-related crimes. 20 The Controlled Substances Act (CSA), enacted as part of the Comprehensive Drug Abuse Prevention and Control Act of 1970, established federal drug policies aimed at preventing U.S. drug abuse. 21 The DEA, which operates under the Department of Justice, leads these counternarcotic efforts and acts as the federal government’s primary authority for regulating and enforcingnarcotic controls. 22 To this end, the DEA works with the U.S. Department of Health and Human Services—specifically the Food and Drug Administration (FDA)—to regulate and control illicit drugs and chemicals. 23 Pursuant to the CSA, the DEA and FDA are jointly charged with updating and revising the list of controlled and banned chemicals by classifying them into five schedules of controlled substances. 24 Most fentanyl products are either Schedule I chemicals—meaning they have no accepted medical use and a high potential for abuse—or Schedule II chemicals, which have a strong potential for abuse but some legitimate medical uses. 25 Because the process for scheduling chemicals is time intensive, the DEA has increasingly utilized temporary scheduling procedures to introduce interim restrictions on substances while they are considered for permanent scheduling. 26 Along with regulating chemicals, the DEA also coordinates with several other federal agencies to support enforcement efforts. 27 Among the agencies that work with the DEA to investigate and enforce drug laws are the Federal Bureau of Investigation; the U.S. Marshals Service; the Bureau of Alcohol, Tobacco, Firearms, and Explosives; the U.S. Department of Homeland Security; and the U.S. Postal Inspection Service. 28 In addition, the DEA coordinates with the White House Office of National Drug Control Policy, which engages with foreign governments and domestic programs to ensure a coordinated and comprehensive counternarcotic approach. 29 The DEA also works with the White House’s High Intensity Drug Trafficking Areas Program, which has funded 752 federal and local initiatives to prevent and treat drug use, share intelligence among law enforcement agencies, and assess narcotic threats at the federal, state, and local levels. 30 As drug trafficking has increased nationwide, federal drug agencies—and the DEA in particular—have ramped up cooperation with their state and local counterparts, providing financial and personnel support for state-led counternarcotic enforcement operations. 31 In 2016, for instance, the DEA State and Local Task Force Program managed 271 state and local task forces and provided over 2,200 DEA special agents to work in conjunction with more than 2,500 state and local officers to enhance enforcement and detection capabilities. 32 Although U.S. states and territories have their own regulatory framework to enforce drug laws, the DEA and FDA can place chemicals on the U.S. list of controlled substances, thereby banning or controlling them nationwide. 33 Thus, states have less authority than the federal government to shape counternarcotic regulations, with scheduling decisions made by the DEA and FDA superseding those made at the state level. 34

The White House and Congress have sought to enhance the DEA and other agencies’ abilities to combat chemical flows and production. In 2012, for example, the Synthetic Drug Abuse Prevention Act was signed into law to enhance counternarcotic enforcement and streamline the DEA’s role in detection and enforcement. 35 The Synthetic Drug Abuse Prevention Act banned more than 20 chemical compounds used in synthetic drugs, doubled the review period for temporarily scheduled substances from 18 to 36 months, and expanded the DEA’s temporary scheduling authority to allow the DEA to more quickly ban new chemicals. 36 In 2016, bills were introduced in the U.S. House of Representatives (H.R. 3537) and U.S. Senate (S. 3224) that would have added 22 substances to the CSA, including three derivatives of fentanyl (butyryl fentanyl, beta-hydroxythiofentanyl, and acetyl fentanyl). 37 In January 2017, a resolution was introduced in the Senate (S. 10) to name the use of illicit fentanyl a public health crisis in the United States, encourage further measures to increase fentanyl treatment and prevention, and support additional efforts in partnership with the Mexican and Chinese governments to reduce trafficking. 38

Fentanyl Flows from China

According to U.S. law enforcement and drug investigators, China is the main supplier of fentanyl to the United States, Mexico, and Canada. 39 Because illicit fentanyl is not widely used in China, authorities place little emphasis on controlling its production and export. 40 Chinese chemical manufacturers export a range of fentanyl products to the United States, including raw fentanyl, fentanyl precursors, fentanyl analogues, * fentanyl-laced counterfeit prescription drugs like oxycodone, and pill presses and other machinery necessary for fentanyl production. 41 These products are sent to small-scale drug distributors and criminal organizations across the United States who package and sell the product. 42 According to the DEA, hundreds of thousands of counterfeit pills—some containing deadly amounts of fentanyl—as well as an unknown quantity of other fentanyl products have been brought into the United States from China over the last several years. 43 Unlike previous opioid epidemics, including a temporary spike in U.S. fentanyl use in 2006 that was traced to a single clandestine lab in Mexico, fentanyl sold in the United States is now being processed by many individual distributors across the country. 44 The diffused nature of the problem has made it difficult for law enforcement to contain. 45 Illegally obtained pill presses, for example, allow small-scale milling operations in the United States to package between 3,000 and 5,000 pills per hour of illicit fentanyl and other NPS. 46 U.S. law enforcement have already busted several domestic milling operations, including a raid of a clandestine milling operation in a New York residential building in January 2016 that resulted in the seizure of 6,000 fentanyl pills. 47 A similar fentanyl scheme involving three pill presses was discovered and dismantled in Los Angeles two months later. 48 The equipment and materials needed for illicit fentanyl production are easily obtainable from China, reducing the barriers to entry for illicit producers and increasing the availability of fentanyl and other NPS. 49

Quote
* Fentanyl analogues have chemical structures differing only slightly from the pharmaceutical-grade version of the drug. Karen Howlett et al., “How Canada Got Addicted to Fentanyl,” Globe and Mail, August 24, 2016. xttp://www.theglobeandmail.com/news/investigations/a-killer-high-how-canada-got-addicted-tofentanyl/article29570025/.

According to the DEA, Chinese fentanyl exports are also shipped to individuals and organizations in Canada and Mexico (see Figure 2). 50 Mexico is rarely the final destination for illicit drug shipments, however; most fentanyl products sent to Mexico are repackaged and smuggled into the United States. 51 Mexican cartels act as the country’s primary conduit for Chinese fentanyl destined for the United States, purchasing bulk shipments and trafficking it — either alone or mixed with other drugs like heroin—across the U.S. border. 52 The illicit nature of these smuggling operations makes it difficult to quantify the volume of fentanyl flows from Mexico to the United States, but public reporting suggests synthetic opioids are increasingly being trafficked across the southwest border of the United States or delivered through mail couriers. 53 In 2015, U.S. border agents seized around 200 pounds of fentanyl and other synthetic opioids from Mexico, up from just eight pounds in 2014. 54 According DEA officials, fentanyl trafficking from Canada to the United States is limited when contrasted with flows from Mexico and China. 55 In response to the growing fentanyl crisis, the U.S. and Chinese governments have taken steps to address illicit chemical flows. In October 2015, China added 116 synthetic chemicals—including six fentanyl products—to its list of controlled chemical substances. * In all, China now controls for 19 types of fentanyl-related substances, although many fentanyl precursors, including N-Phenethyl-4-piperidinone (NPP), are still not controlled (for a full list of known fentanyl precursors, see Appendix I, “Fentanyl Precursors”). 56 According to a factsheet released by the U.S. National Security Council following the G20 Summit in September 2016, China has also “committed to targeting U.S.-bound exports of substances controlled in the United States, but not in China,” † along with a vague agreement between the two countries to improve coordination and information sharing on controlled substances and chemicals of concern. 57 Additionally, in October 2016 U.S. Secretary of State John Kerry wrote a letter to the UN secretary-general requesting that NPP and anilino-N-phenethylpiperidine (ANPP), two of the most common precursor chemicals used to manufacture fentanyl, be added to the list of controlled chemicals under the 1988 U.N. Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances. 58 In the letter, Secretary Kerry asked that the UN Commission on Narcotic Drugs be ready to make a decision on controlling fentanyl precursors during its next meeting in March 2017. 59 China is an original signatory to the 1988 UN Convention, and thus would be bound to abide by the Commission’s ruling. 60

Quote
* The fentanyl products banned in China in October 2015 include acetyl-fentanyl, butyryl-fentanyl, beta-hydroxythio-fentanyl, para-fluoro-fentanyl, iso-butyr-fentanyl, and ocfentanyl. China Food and Drug Administration, Notification of the Issuance of Managing Non-Medicinal Narcotics and Psychoactive Drugs, September 29, 2015. Staff translation. http://www.sfda.gov.cn/WS01/CL0056/130753.html.

† A factsheet released by China’s Ministry of Foreign Affairs following the G20 Summit indicated that the United States and China will exchange lists of synthetic drugs and drug analogues. However, the Chinese statement did not include a commitment to target U.S.-bound exports of substances controlled in the United States that are not controlled in China. China’s Ministry of Foreign Affairs, List of Achievements from Sino-US Head of State Meeting in Hangzhou, September 4, 2016. Staff translation. xttp://www.fmprc.gov.cn/web/zyxw/t1394413.shtml.

Figure 2: Illicit Fentanyl and Fentanyl Precursor Flows from China SEE ATTACHED PDF

China’s Chemical and Pharmaceutical Production

China is a global source of illicit fentanyl and other NPS because the country’s vast chemical and pharmaceutical industries are weakly regulated and poorly monitored. * China’s pharmaceutical market is the second largest in the world by revenue, consisting of more than 5,000 companies with a revenue of $105 billion in 2014 (the United States’ $380 billion pharmaceutical industry is the largest in the world). 61 Unlike the United States, which produces costly, high-value compounds, China’s pharmaceutical industry relies on mass production of inexpensive generic drugs and pharmaceutical ingredients for revenue. 62 The Chinese government has prioritized pharmaceutical production as a “high-value-added industry,” providing export tax rebates to encourage pharmaceutical companies to export their products. 63 As a result, China is currently the world’s largest manufacturer and top exporter of pharmaceutical ingredients. 64

In addition, China’s numerous nonpharmaceutical chemical companies legally produce massive quantities of chemicals every day. 65 The U.S. Department of State estimates that nationwide, China has more than 160,000 chemical companies operating legally and illegally, with some facilities manufacturing tons of chemicals every week and others producing over one million pills daily. 66 China’s total profits from chemical production increased to $60 billion in the first 11 months of 2015, up 6.8 percent compared to the same period in 2014. 67 Although specific data on China’s production and export of fentanyl and its analogues are not available, documents attached to Secretary Kerry’s letter to the UN secretary-general indicated that of the more than 178 global suppliers of NPP and 79 global suppliers of ANPP, more than half are located in China. 68

Quote
* For more on China’s pharmaceutical and chemical industries and exports of illicit chemicals to the United States, see Sean O’Connor, “Meth Precursor Chemicals from China: Implications for the United States,” U.S.-China Economic and Security Review Commission, July 18, 2016. xttp://origin.www.uscc.gov/sites/default/files/Research/Staff%20Report_PrecursorChemicalReport%20071816_0.pdf.

Chinese law enforcement and drug investigators are unable to effectively regulate the high volume of drugs and chemicals the country produces. 69 In many cases, the chemicals used to produce fentanyl and fentanyl-like products are illegally diverted from legitimate pharmaceutical uses, with criminals taking advantage of inadequate enforcement protocols to produce unregulated chemicals and NPS. 70 Until 2014, a regulatory loophole allowed Chinese chemical companies to operate in a gray area of oversight, freeing them from inspection requirements and other certification systems. 71 That loophole was closed in 2014 when China’s State Administration of Work Safety implemented new regulations on chemical production to improve management of nonpharmaceutical businesses, including enforcing stricter licensing requirements. 72

Even under the new regulations, Chinese pharmaceutical and chemical companies continue to divert chemicals from legitimate pharmaceutical uses and adulterate legitimate pharmaceuticals during production. 73 This makes drug enforcement within China difficult, as many manufacturers of fentanyl and other NPS are legitimate companies legally producing chemicals. 74 Although some of these chemical manufacturers knowingly ship their products to the United States for illicit purposes, Chinese chemical and pharmaceutical exporters continue to operate with little oversight. 75 An October 2016 investigation by the Associated Press, for instance, identified 12 Chinese businesses that would export lethal synthetic opioids to the United States without any hesitation. 76 In an interview with National Public Radio, David Armstrong, a reporter for the online health news site STAT News, explained that many Chinese law enforcement officials appear to make little effort to uncover the source of the buyer or determine whether the products will be used for a legitimate purpose. 77 The United States’ ability to conduct drug inspections in China has also been obstructed by Chinese regulators, with several recorded instances of Chinese law enforcement and drug regulators delaying visa approvals for FDA officials and deleting laboratory test records. 78 The Chinese government, however, maintains that U.S. claims of China-sourced opioid shipments are exaggerated. 79

China’s regulatory shortcomings are exacerbated by the fragmented and disorganized administrative system overseeing chemical production and exports. 80 Chinese government agencies involved in drafting, overseeing, and enforcing chemical regulations and export requirements include the China Food and Drug Administration, State Council Leading Group on Product Quality and Food Safety, National Narcotics Control Commission, Anti-Smuggling Bureau within the General Administration of Customs, Ministry of Chemical Industry, Ministry of Agriculture, Ministry of Commerce, and General Administration of Quality Supervision, Inspection, and Quarantine. 81 With so many agencies involved in regulating chemical production and exports, bureaucratic infighting can prevent the government from carrying out precise and effective counternarcotic operations. 82

Deficient local drug inspection and enforcement capabilities, coupled with corrupt practices among local officials, also limit the effectiveness of China’s chemical regulations. 83 With thousands of pharmaceutical companies and hundreds of thousands of chemical companies around the country churning out massive quantities of products daily, regulators are unable to adequately inspect all production and distribution facilities. 84 Instead, Chinese law enforcement personnel are mainly concentrated in urban centers, leading to increased drug activity in rural areas and poorer communities. 85 According to Jeremy Haft, a professor at Georgetown University, the insufficient presence of law enforcement has made it easy for small, unregistered drug labs to evade authorities. 86 Professor Haft explains, “If there’s a threat of law enforcement, [the chemical company can] shut down quickly and disappear, only to open up again in another form somewhere else.” 87 Compounding the problem is China’s rampant corruption, particularly among local leaders who may actively work to undermine chemical production regulations. 88 Although Beijing has begun cracking down on local government corruption in recent years—expelling 41 officials from Yunnan Province for drug use in 2014—many officials are still susceptible to bribery from drug producers, particularly in localities where regulators are underpaid and overworked. 89

Chinese Exporters Circumvent U.S. Chemical Regulations

The increasing sophistication of Chinese chemical exporters poses new challenges to U.S. counternarcotic efforts. 90 The Internet in particular has contributed to fentanyl’s increased availability in North America. 91 Not only can all forms of chemicals and fentanyl-making products be bought online at relatively low prices from Chinese distributors, but chemical manufacturers in China are also able to mask their identities using online ordering systems. 92 One popular online marketplace for synthetic drugs is the English-language website of China Enriching Chemistry, a Shanghai company, where distributors and consumers of illicit chemicals buy and sell illicit substances anonymously (see Figure 3). 93 Such online marketplaces eliminate many of the market barriers and significantly reduce the risks associated with purchasing fentanyl. 94 In addition, fentanyl products are often mailed through a chain of forwarding systems, further limiting authorities’ ability to track and identify the source of the shipment. 95 In fact, avoiding detection has become so simple that many Chinese narcotic distributors will guarantee customers a second shipment if the first is seized by law enforcement. 96

Figure 3: Example of a Chinese Online Marketplace for Synthetic Drugs SEE ATTACHED PDF
Source: Dan Levin, “In China, Illegal Drugs Are Sold Online in an Unbridled Market,” New York Times, June 21, 2015. xttp://www.nytimes.com/2015/06/22/world/asia/in-china-illegal-drugs-are-sold-online-in-an-unbridled-market.html?_r=0.

Chemical exporters in China also avoid detection by mislabeling shipments. 97 Fentanyl suppliers use various methods to mislabel shipments, with some concealing the powder in silica packages placed alongside everyday items. 98 Others giftwrap shipments or label them as household products like detergent to avoid detection. 99 Shipments of pill presses from China are also mislabeled to evade U.S. regulations, with many Chinese exporters shipping pill presses part by part to avoid additional scrutiny from customs officials. * 100 While it is difficult to estimate the total volume of fentanyl products being imported in mislabeled shipments, reports indicate these operations are occurring on a massive scale. In July 2013, for example, one Chinese supplier transported nearly 2,000 pounds of controlled chemicals to Florida by sending separate shipments, each containing four to seven pounds of the illicit chemicals. 101

In addition, U.S. law enforcement officials are often unable to identify and seize potentially harmful drugs or precursor chemicals because Chinese manufacturers modify the chemicals to create new, unregulated substances. 102 After banning fentanyl exports as part of the 116 banned chemicals announced in October 2015, for example, Chinese manufacturers began producing and openly selling a new form of the drug called furanyl fentanyl. 103 Because of its modified chemical structure, furanyl fentanyl was not controlled in the United States or China, and thus could not be seized by U.S. authorities until September 2016, when it was classified as a Schedule I drug. † 104 This cycle is emblematic of what DEA spokesman Russell Baer describes as “a challenging process” for scheduling chemicals. 105 In an interview with STAT News in April 2016, Mr. Baer explained that the DEA “will seek to put furanyl fentanyl on the list [of controlled substances], and then [the Chinese] will tweak one molecule, and in two months we will be discussing that one.” 106 After furanyl fentanyl was scheduled and controlled, a new drug called carfentanil entered into circulation. 107 Carfentanil is an animal tranquilizer that is 100 times more potent than fentanyl, and has been linked to overdoses across the country, including in Kentucky, Florida, and Ohio. 108 Although carfentanil is controlled in the United States, it is not controlled in China, where it is legally produced and sold. 109 Even if China bans carfentanil, however, counternarcotic experts warn it will only lead to the export of new synthetic substances, much like how bans on fentanyl and furanyl fentanyl led to increased exports of carfentanil. 110

Quote from: Happless
NOTE: China banned Carfentanil in early 2017. Other than that, the above is correct.

Drugs trafficked into the United States from Mexico present an additional avenue for Chinese exporters to evade U.S. regulations. 111 As another major destination of Chinese fentanyl exports, Mexico faces the same regulatory challenges as the United States, with online ordering systems, mislabeled shipments, and modified chemicals limiting officials’ ability to implement effective counternarcotic enforcement and tracking mechanisms. 112 Compounding these problems are reports that Mexican officials remain wary of enforcing more stringent fentanyl policies. 113 According to a June 2016 article in the Wall Street Journal, an unnamed Mexican official indicated the Mexican government is hesitant to press China too aggressively on fentanyl trade for fear of economic retribution. 114 Although no other public evidence exists to date that supports these claims, the Mexican government’s unwavering cooperation with international counternarcotic efforts is essential to combatting flows of fentanyl and other NPS from China.

Quote
* Although the United States requires all pill press imports to be reported and approved by the DEA, there are no laws in China regulating the production or sale of pill presses. Records and Reports of Listed Chemicals and Certain Machines, codified at 21 C.F.R. § 1310.05(c) (2015); U.S. Drug Enforcement Administration, Counterfeit Prescription Pills Containing Fentanyls: A Global Threat, July 2016, 7. xttps://www.dea.gov/docs/Counterfeit%20Prescription%20Pills.pdf.
† Schedule I drugs have no accepted medical use and a high potential for abuse. Schedules of Controlled Substances: Temporary Placement of Furanyl Fentanyl into Schedule I, codified at 21 C.F.R. § 1308 (September 2016).

Conclusions

Because the majority of fentanyl products found in the United States originate in China, it is essential for U.S. counternarcotic personnel to enhance cooperation with their Chinese counterparts. 115 The Chinese government has strengthened regulations governing chemical and pharmaceutical production—including a crackdown on local government corruption and scheduling a range of new NPS—yet Chinese law enforcement and drug investigators remain unable to effectively regulate the high volume of drugs and chemicals the country produces. In many cases, the chemicals used to produce fentanyl and fentanyl-like products are diverted from legitimate pharmaceutical uses in China, with criminals taking advantage of inadequate enforcement protocols to produce unregulated chemicals and NPS.

Although the primary obstacles to controlling fentanyl and NPS flows lie in China, scheduling and chemical control procedures in the United States are also marred by inefficiencies that create a backlog of scheduling requests. Even with legislative efforts streamlining and enhancing counternarcotic enforcement, officials at the U.S. Department of Justice indicate the process for scheduling new chemicals remains time intensive, requiring coordination among several government entities that can stall authorization procedures. 116 Moreover, Chinese exporters continue to replace and modify chemicals in circulation as quickly as they are banned, necessitating further adjustments in scheduling procedures to account for new or altered substances.

Drug analysts and law enforcement personnel have identified the following gaps in counternarcotic enforcement, which have contributed to the ongoing synthetic opioid epidemic in the United States:

• China’s regulations governing chemical production and exports remain fragmented and disorganized, with several government agencies and departments tasked with controlling and enforcing chemical laws.
Because of the many agencies involved, bureaucratic infighting can prevent the Chinese government from carrying out precise and effective counternarcotic operations.

• Under current laws, U.S. drug enforcement agencies like the DEA and FDA must jointly approve new chemical controls. As a result, the process for scheduling new chemicals can be stalled by authorization
procedures, extending the process for permanently controlling new substances that may present an imminent health and safety threat.

• Under current laws, analogues and derivatives of known illicit products must be identified and controlled before they can be seized by drug enforcement personnel. However, U.S. drug enforcement agencies
schedule chemicals one by one, rather than entire classes at a time, delaying seizures of new and potentially dangerous substances. As a result, modified versions of banned chemicals cannot be seized until they are permanently or temporarily controlled.

Appendix

Known Fentanyl Precursors

Quote
N-phenethyl-4-piperdone
1-benzyl-4-piperidone
4-anilino-4-phenethyl-4-piperidine
Aniline
N-[1-(2-phenylethyl)-4-piperidyl]-N-phenylacetamide
Bromoethylbenzene
4-anilino-n-phenethyl-4-piperidine
Chloroethylbenzene
Acetamide N-phenethyl-N-[1-(2-phenethyl)-4-piperidinyl]
Phenethylamine
N-phenethyl-piperidone
4-piperidone
Propionyl chloride
Ethacrylate
Propionic anhydride
Methacrylate

Source: Official, U.S. Drug Enforcement Administration, interview with Commission staff, September 13, 2016.

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89 Xinhua, “China’s Yunnan Expels Drug Addicts from Party,” December 10, 2014. http://www.chinadaily.com.cn/china/2014-12/10/content_19060457.htm; David Volodzko, “China’s Fourth Evil: Drug Trafficking in the PRC,” China Brief 16:6 (March 2016). http://www.jamestown.org/programs/chinabrief/single/?tx_ttnews%5Btt_news%5D=45234#.Vw_WpEwrIdU; U.S.-China Economic and Security Review Commission, Chapter 1, Section 3, “China’s Health Care Industry, Drug Safety, and Market Access for U.S. Medical Goods and Services,” in 2014 Annual Report to Congress, November 2014, 140.
90 Official, U.S. Drug Enforcement Administration, interview with Commission staff, September 13, 2016.
91 U.S. Drug Enforcement Administration, Counterfeit Prescription Pills Containing Fentanyls: A Global Threat, July 2016, 9. https://www.dea.gov/docs/Counterfeit%20Prescription%20Pills.pdf.
92 U.S. Drug Enforcement Administration, Counterfeit Prescription Pills Containing Fentanyls: A Global Threat, July 2016, 9. https://www.dea.gov/docs/Counterfeit%20Prescription%20Pills.pdf.
93 Dan Levin, “In China, Illegal Drugs Are Sold Online in an Unbridled Market,” New York Times, June 21, 2015. http://www.nytimes.com/2015/06/22/world/asia/in-china-illegal-drugs-are-sold-online-in-an-unbridled-market.html?_r=0.
94 U.S. Drug Enforcement Administration, Counterfeit Prescription Pills Containing Fentanyls: A Global Threat, July 2016, 9. https://www.dea.gov/docs/Counterfeit%20Prescription%20Pills.pdf.
95 U.S. Drug Enforcement Administration, Counterfeit Prescription Pills Containing Fentanyls: A Global Threat, July 2016, 8. https://www.dea.gov/docs/Counterfeit%20Prescription%20Pills.pdf.
96 Karen Howlett et al., “How Canada Got Addicted to Fentanyl,” Globe and Mail, August 24, 2016.
http://www.theglobeandmail.com/news/investigations/a-killer-high-how-canada-got-addicted-tofentanyl/article29570025/.
97 U.S. Department of State, 2016 International Narcotics Control Strategy Report (INCSR), March 2016.
http://www.state.gov/j/inl/rls/nrcrpt/2016/vol1/253224.htm.
98 Karen Howlett et al., “How Canada Got Addicted to Fentanyl,” Globe and Mail, August 24, 2016.
http://www.theglobeandmail.com/news/investigations/a-killer-high-how-canada-got-addicted-tofentanyl/article29570025/.
99 Karen Howlett et al., “How Canada Got Addicted to Fentanyl,” Globe and Mail, August 24, 2016.
http://www.theglobeandmail.com/news/investigations/a-killer-high-how-canada-got-addicted-tofentanyl/article29570025/.
100 Official, U.S. Drug Enforcement Administration, interview with Commission staff, September 13, 2016; Jeanne Whalen and Brian Spegele, “The Chinese Connection Fueling America’s Fentanyl Crisis,” Wall Street Journal, June 23, 2016. http://www.wsj.com/articles/the-chinese-connection-fueling-americas-fentanyl-crisis-1466618934.
101 U.S. Department of Justice, Chinese Chemical Supplier Pleads Guilty to Conspiracy and Importation of Synthetic Drugs, Controlled Substances, March 13, 2015. https://www.justice.gov/usao-mdfl/pr/chinese-chemical-supplier-pleads-guilty-conspiracy-and-importation-synthetic-drugs.
102 Peter Holley and William Wan, “Morning Mix Deadly Chinese Drugs Are Flooding the U.S., and Police Can’t Stop Them,” Washington Post, June 22, 2015. https://www.washingtonpost.com/news/morning-mix/wp/2015/06/22/deadly-chinese-drugs-are-flooding-the-u-s-and-police-cant-stop-them/.
103 David Armstrong, “Chinese Labs Modify Deadly Fentanyl to Circumvent Ban on Sales to US,” STAT News, April 26, 2016. https://www.statnews.com/2016/04/26/chinese-sell-modified-fentanyl/.
79 U.S.-China Economic and Security Review Commission
16U.S. Drug Enforcement Administration, Drug Scheduling. https://www.dea.gov/druginfo/ds.shtml; David Armstrong, “Chinese Labs Modify Deadly Fentanyl to Circumvent Ban on Sales to US,” STAT News, April 26, 2016.
https://www.statnews.com/2016/04/26/chinese-sell-modified-fentanyl/.
105 David Armstrong, “Chinese Labs Modify Deadly Fentanyl to Circumvent Ban on Sales to US,” STAT News, April 26, 2016. https://www.statnews.com/2016/04/26/chinese-sell-modified-fentanyl/.
106 David Armstrong, “Chinese Labs Modify Deadly Fentanyl to Circumvent Ban on Sales to US,” STAT News, April 26, 2016. https://www.statnews.com/2016/04/26/chinese-sell-modified-fentanyl/.
107 David Kroll, “Clandestine Opioid Furanyl Fentanyl Will Be Assigned to Schedule I, DEA Says,” Forbes, September 30, 2016. http://www.forbes.com/sites/davidkroll/2016/09/30/clandestine-opioid-furanyl-fentanyl-will-be-assigned-to-schedule-i-dea-says/#25c6071d38a9.
108 Brian MacQuarrie, “Opioid Epidemic’s Newest Killer Is 10,000 Times Stronger than Morphine,” Boston Globe, October 16, 2016. https://www.bostonglobe.com/metro/2016/10/16/region-braces-for-arrival-new-more-powerful-synthetic-opioid/uLdoivGZdopm468poRzU3J/story.html; Keegan Hamilton, “America’s New Deadliest Drug Is Fentanyl,” Vice News, August 30, 2016. https://news.vice.com/article/americas-new-deadliest-drug-fentanyl.
109 Associated Press, “Chinese Companies Willing to Export Deadly Opioid Carfentanil to Canada and U.S.” October 7, 2016. http://globalnews.ca/news/2989553/chinese-companies-willing-to-export-deadly-opioid-carfentanil-to-canada-and-u-s/.
110 Max Plenke, “This Is How Chinese Labs Are Sneaking the Dangerous Drug Fentanyl into the US,” Science Mic, April 26, 2016. https://mic.com/articles/141850/chinese-labs-are-sneaking-drug-fentanyl-into-the-us#.UPFvkVix0; Baidu Baijia (Blog), “China’s Chemical Industry Business to Business (B2B) Development Report,” August 15, 2016.
111 U.S. Drug Enforcement Administration, Counterfeit Prescription Pills Containing Fentanyls: A Global Threat, July 2016, 7. https://www.dea.gov/docs/Counterfeit%20Prescription%20Pills.pdf.
112 Jeanne Whalen and Brian Spegele, “The Chinese Connection Fueling America’s Fentanyl Crisis,” Wall Street Journal, June 23, 2016. http://www.wsj.com/articles/the-chinese-connection-fueling-americas-fentanyl-crisis-1466618934.
113 Jeanne Whalen and Brian Spegele, “The Chinese Connection Fueling America’s Fentanyl Crisis,” Wall Street Journal, June 23, 2016. http://www.wsj.com/articles/the-chinese-connection-fueling-americas-fentanyl-crisis-1466618934.
114 Jeanne Whalen and Brian Spegele, “The Chinese Connection Fueling America’s Fentanyl Crisis,” Wall Street Journal, June 23, 2016. http://www.wsj.com/articles/the-chinese-connection-fueling-americas-fentanyl-crisis-1466618934.
115 U.S.-China Ec
3
I read this recently, and thought the people here would be interested to read it too. It is really a great look at CBP's drug and chemical interdiction efforts and capabilities concerning smuggled and mislabeled contraband. It's definitely worth your time to read if you are concerned at all with the importation of drugs or chemicals into US territory through US customs.

*** TESTIMONY from xttps://www.dhs.gov/news/2017/09/07/written-testimony-cbp-house-oversight-and-government-reform-subcommittee-government

"Chairman Meadows, Ranking Member Connolly, and distinguished Members of the Subcommittee, thank you for the opportunity to appear today to discuss the role of U.S. Customs and Border Protection (CBP) in combating the flow of dangerous illicit drugs into the United States, specifically through international mail and express consignment carrier (ECC) shipments."

Written testimony of CBP Office of Field Operations Executive Assistant Commissioner Todd Owen for a House Committee on Oversight and Government Reform, Subcommittee on Government Operations hearing titled “Examining the Shipment of Illicit Drugs in International Mail”

Release Date: September 7, 2017

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Written testimony of CBP Office of Field Operations Executive Assistant Commissioner Todd Owen for a House Committee on Oversight and Government Reform, Subcommittee on Government Operations hearing titled “Examining the Shipment of Illicit Drugs in International Mail” Chairman Meadows, Ranking Member Connolly, and distinguished Members of the Subcommittee, thank you for the opportunity to appear today to discuss the role of U.S. Customs and Border Protection (CBP) in combating the flow of dangerous illicit drugs into the United States, specifically through international mail and express consignment carrier (ECC) shipments.

As America’s unified border agency, CBP plays a critical role in the Nation’s efforts to keep dangerous drugs from harming the American public. CBP’s Office of Field Operations (OFO) interdicts drugs at our ports of entry (POEs) and multiple mail and ECC facilities, leveraging targeting and intelligence-driven strategies, and working with our partners to combat Drug Trafficking Organizations (DTOs) as part of our multi-layered, risk-based approach to enhance the security of our borders. This layered approach reduces our reliance on any single point or program and extends our zone of security outward ensuring our physical border is not the first or last line of defense, but one of many.

Illicit Drug Trends, Interdictions, and Challenges

While most illicit drug smuggling attempts occur at Southwest land POEs, the smuggling of illicit synthetic drugs in the mail and ECC environment is a growing threat that we need to work to address. Several different types of illicit synthetic drugs, also called “designer drugs”, are currently being sold and shipped to end-users in the United States, including synthetic opioids such as fentanyl,1 synthetic cannabinoids,2 and synthetic cathinones.3 CBP seizures of fentanyl, the most frequently seized synthetic opioid,4 remain relatively small compared to other opioids such as heroin,5 but have significantly increased over the past three years, from approximately two pounds seized in Fiscal Year (FY) 2013 to approximately 544 pounds seized in FY 2016.6

Illicit synthetic drugs are often purchased from foreign sellers through online transactions. The drugs are then shipped to the United States and delivered to domestic purchasers – DTOs and individuals – primarily via U.S. mail or ECC. DTOs and individual purchasers move synthetic drugs such as fentanyl in small quantities, making detection and targeting a significant challenge. Follow-on investigations, which are conducted by U.S. Immigration and Customs Enforcement – Homeland Security Investigations (ICE-HSI), are also challenging because these shippers often are not the hierarchically structured DTOs we usually encounter.

In FY 2017 to date,7 CBP has made 90 seizures of fentanyl totaling approximately 217 lbs. in the ECC environment and 152 seizures totaling approximately 82 lbs. of fentanyl in the international mail environment. CBP has also made 46 seizures at land POEs totaling approximately 494 lbs.; however, the average purity of fentanyl in the international mail and ECC environments is over 90 percent, whereas the average purity of fentanyl in the land border environment is only 7 percent. Purchasers can also access open source and dark web marketplaces for the tools needed for manufacturing synthetic drugs. In the case of fentanyl, powdered fentanyl, pill presses, and binding agents can be purchased online and then shipped into the United States.8 In FY 2014, 24 pill press/tablet machines were seized by CBP, and the number increased to 51 in FY 2015 and 58 in FY 2016.

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1 Along the Southwest border, the practice of mixing synthetic opioids into heroin makes it more challenging for CBP to accurately quantify how much synthetic opioid is seized at the border.
2 Synthetic cannabinoids are drugs that do not contain marijuana but are pharmacologically similar to tetrahydrocannabinol. (xttps://www.cdc.gov/mmwr/volumes/65/wr/mm6527a2.htm)
3 Synthetic cathinones, more commonly known as "bath salts," are synthetic drugs chemically related to cathinone, a stimulant found in the khat plant. (xttps://www.drugabuse.gov/publications/drugfacts/synthetic-cathinones-bath-salts)
4 While fentanyl is the most frequently-seized synthetic opioid, CBP has also encountered various types of fentanyl analogues, including acetylfentanyl, butyrylfentanyl, beta-hydroxythiofentanyl, para-fluorobutyrylfentanyl, pentanoylfentanyl, alpha-methyl acetylfentanyl, para-fluoroisobutyrylfentanyl, para-fluorofentanyl, carfentanil, furanylfentanyl, and most recently benzodioxolefentanyl, acrylfentanyl, and methoxyacetylfentanyl. Also, CBP’s Laboratories and Scientific Services Directorate (LSSD) has presumptively identified n-hexanoyl fentanyl and benzoyl fentanyl, and are working diligently to confirm these new substances.
5 In FY 2016, CBP officers and agents seized or disrupted more than 3.3 million pounds of narcotics across the country, including approximately 46,000 pounds of methamphetamine, approximately 200,000 pounds of cocaine, and approximately 4,800 pounds of heroin. xttps://www.cbp.gov/sites/default/files/assets/documents/2016-Dec/CBP-fy2016-border-security-report.pdf.
6 This includes approximately 440 pounds seized at POEs (including mail and ECC facilities) and 104 pounds seized at U.S. Border Patrol checkpoints.
7 As of August 27, 2017.
8 U.S. law enforcement suspects that there are also some clandestine fentanyl production labs in Mexico that likely obtain precursor chemicals from China.

International Mail and Express Consignment Carrier Operations

In the ECC environment, shipments are processed at 26 facilities located throughout the United States. Prior to arrival of the express parcels, CBP reviews the manifest information transmitted by the ECC operators and targets those packages requiring examination. All parcels presented to CBP for examination are subjected to Non-Intrusive Inspection (NII) to include x-ray and gamma ray imaging. CBP operates in all 26 facilities nationwide.

CBP also operates within nine International Mail Facilities (IMF), inspecting international mail arriving from more than 180 countries. Upon arrival in the United States, all international mail parcels are screened for radiological threats. International mail requested for inspection by CBP is then turned over to CBP by the United States Postal Service (USPS). CBP x-rays all international mail packages presented by USPS and physically examines those deemed to be high-risk.

Currently, in the international mail environment, there is limited advance information available. The lack of advanced manifest data, which would aid in targeting shipments, as well as the sheer volume of mail and potentially hazardous nature of various types of illicit drugs, present challenges to CBP’s interdiction efforts in the international mail environment. The detection of illicit synthetic drugs in particular remains challenging. Illicit drug manufacturers seek to outpace the law by continually manufacturing new drug analogues, challenging CBP’s targeting and detection capabilities.

Although the processing of inbound international mail is primarily manual, requiring CBP officers to sort through large volumes of parcels, CBP officers utilize experience and training to identify items that potentially pose a risk to homeland security and public safety while facilitating the movement of legitimate mail. On April 20, 2017, CBP officers working at the IMF in Chicago, Illinois, intercepted a package from China destined for Lafayette, Indiana, that was not manifested and had no declared value. CBP officers selected the package for further examination due to prior seizures utilizing similar packaging. A physical examination of the package revealed 2.27 pounds of a fentanyl analogue. CBP has also worked in coordination with local police departments, as in the case of a man arrested in Rohnert Park, California, in late 2016 for collecting a package shipped internationally through the mail containing $30,000 worth of MDMA, also called Ecstasy or Molly.9

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9 Per xttp://www.sfchronicle.com/crime/article/Rohnert-Park-man-busted-in-club-drug-smuggling-10623082.php?ipid=gsa-sfgate-result

CBP Resources and Capabilities to Target, Detect, and Interdict Illicit Drugs

Thanks to the support of Congress, CBP has made significant investments and improvements in our drug detection, identification, and targeting capabilities. These resources, along with enhanced information sharing and partnerships, are critical components of CBP’s ability to detect and deter the entry of dangerous illicit drugs in the international mail and ECC environments.
Advance Information and Targeting

An important element of CBP’s layered security strategy is obtaining advance information to help identify shipments that are potentially at a higher risk of containing contraband. Under the Security and Accountability for Every Port Act or SAFE Port Act of 2006, (Pub. L. No. 109-347), CBP has the legal authority to collect key air and maritime cargo data elements provided by air, sea, and land commercial transport companies (carriers) — including ECCs and importers. This information is automatically fed into CBP’s Automated Targeting System, an intranet-based enforcement and decision support system that compares cargo and conveyance information against intelligence and other enforcement data.

CBP’s National Targeting Center (NTC) is where advance data and access to law enforcement and intelligence records converge to facilitate the targeting of travelers and items of cargo that pose the highest risk to our security — in all modes of inbound transportation. The NTC takes in large amounts of data and uses sophisticated targeting tools and subject matter expertise to analyze, assess, and segment risk at every stage in the cargo/shipment and travel life cycles. As the focal point of that strategy, the NTC leverages classified, law enforcement, commercial, and open-source information in unique, proactive ways to identify high-risk travelers and shipments at the earliest possible point prior to arrival in the United States.

Because of the complex tracking systems used by ECCs, when CBP identifies a high-risk shipment in the ECC environment, it has the ability to place an electronic hold and to notify the carrier that a particular parcel needs to be presented to CBP for inspection. The major international air shipping carriers have a tracking number system that allows them to pull these parcels for inspection when they are scanned into the computer system upon arrival at an air hub.

As mentioned above, in the international mail environment, there is limited advance information available. USPS receives mail from more than 180 countries, the vast majority of which arrives via commercial air or surface transportation. The international mail system is not integrated and few foreign postal administrations provide advance manifest data to USPS (which may then be passed on to CBP). Hence, within the mail environment, CBP Officers must rely on intelligence and physical or x-ray examinations to carry out their enforcement mission. CBP and the USPS have been conducting an advance data pilot on express mail and e-packets from select countries, and CBP continues to work with the USPS to address the issue of electronic advanced data and, through its participation on U.S. delegations to meetings of the Universal Postal Union, is working to expand its use globally.10
Detection Technology and Canines

CBP officers utilize NII, spectroscopic and chemical testing equipment, and detection canines to detect and identify illicit drugs at international mail and ECC facilities. Canine operations are an invaluable component of CBP’s counternarcotic operations. CBP canine teams work at international mail facilities to examine millions of foreign mail shipments coming into the United States from all parts of the world. Synthetic opioids present unique challenges to canine teams due to the potency of the drug and the associated danger to the health and safety of the canines and their handlers. CBP recently assessed the feasibility of safely and effectively adding fentanyl as a trained odor to OFO’s deployed narcotic detection canine teams.11 On June 23, 2017, CBP successfully completed its first Fentanyl Detection Canine Pilot Course, which added the odor of fentanyl and its analogues to six OFO canine handler teams. CBP continues to conduct special research to determine the detection and identification of signature odor profiles for fentanyl compounds to aid in our detection capabilities.

The narcotics seized through the mail and at ECC facilities usually have a very high purity compared to seizures along the Southwest border due to the DTO practice of mixing synthetic opioids with other substances.12 Therefore, at IMFs and ECC facilities, CBP officers use Fourier Transform Infrared Spectroscopy (FT-IR), Gemini Raman Spectroscopy,13 handheld narcotics analyzers, and NIK narcotic field drug test kits14 to test suspect substances and obtain a presumptive result. When illicit drugs are seized at an IMF or ECC facility, the sample data is then transmitted directly to CBP’s Laboratories and Scientific Services Directorate (LSSD) for scientific identification and interpretation.

CBP also performs illicit synthetic drug detection in the field with LSSD’s Field Triage Infrared Reachback Program, which utilizes ruggedized FTIR equipment, the data from which is transmitted from officers in the field to scientific personnel at LSSD to provide presumptive results. When any synthetic opioids are detected by the reachback program, LSSD notifies key CBP personnel at the NTC as well as the liaisons with DEA’s Special Operations Division, so they can generate near real-time intelligence and see if controlled deliveries can be executed. LSSD is working to expand the field testing program, along with the scientific assets and personnel who are able to provide real-time chemical composition determinations.15

In the fourth quarter of FY 2016, OFO conducted a pilot with the San Diego Field Office and the LSSD Los Angeles Laboratory to evaluate new testing methods for the identification of fentanyl. The pilot tested four handheld tools along with a new reagent test kit to provide immediate presumptive testing for fentanyl. Of the four tested, the Gemini Analyzer proved to be the most reliable instrument. The Gemini system combines Raman with FT-IR technology and encompasses a software library that evaluates and identifies liquid and chemical explosives. Based on the results of the pilot, OFO procured twelve Gemini systems and assigned a Program Manager to provide a Fentanyl Safety Brief for the CBP officers across San Diego, Tucson, El Paso, and Laredo Field Offices. Currently, OFO is working to procure more than 60 additional handheld analyzers, test kits, and the necessary protective equipment to conduct non-contact sampling on-site. The systems will be deployed in the mail and ECC cargo facilities and at POEs on the Southwest border. CBP will prioritize procurement and deployment plans of additional devices based on the availability of funds and analysis of synthetic drug interdiction rates.

Technology and canine detection capabilities are critical components of CBP’s security operations at mail and ECC cargo facilities. These capabilities are used in conjunction with advance information and targeting capabilities to effectively and efficiently detect and interdict dangerous illicit drugs.
Workforce Protection

CBP’s frontline operations, including drug interdiction activities, are extremely hands-on. The potential for contact with dangerous substances – especially illicit synthetic opioids – is a very real health and safety risk to law enforcement personnel and canines. For example, in its pure powder form, fentanyl is approximately 50-100 times more potent in its intensity, speed of action, and effect on organs than morphine, and, at first glance, it is often mistaken for other drugs, which appear as white powders such as cocaine or heroin. Due to the risk of unintentional exposure and subsequent hazardous drug absorption and/or inhalation, the confirmatory testing for the presence of synthetic opioids such as fentanyl is best executed in a laboratory by trained scientists and technicians.16

Explicit instructions, including guidance to canine handlers, have been distributed to the field regarding the safe handling of fentanyl. Additionally, in response to increased seizures at LPOEs and the upsurge in the use of heroin (which is increasingly cut with fentanyl) across the Nation, in October 2015 CBP completed Phase 1 of a pilot program to train and equip CBP officers with naloxone, a potentially life-saving drug for the treatment of opioid exposure. During Phase I, CBP officers, at seven participating POEs17 received training on recognizing the signs and symptoms of opioid exposure, administering naloxone, and were certified as CPR instructors. In February 2016, CBP initiated Phase 2 of the Naloxone Initiative Pilot Program, expanding the pilot to an additional eight POEs and deploying 602 dual-dose Narcan Nasal Spray® kits to the field.18 The naloxone program has also expanded to LSSD to help protect its scientists both in its main and satellite laboratories. CBP was the first Federal law enforcement agency to implement such a program.

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10 49 U.S.C. 44901(a) states: “The Under Secretary of Transportation for Security shall provide for the screening of all passengers and property, including United States mail, cargo, carry-on and checked baggage, and other articles, that will be carried aboard a passenger aircraft.” Under 49 C.F.R. 1540.5, “Cargo means property tendered for air transportation accounted for on an air waybill. All accompanied commercial courier consignments whether or not accounted for on an air waybill, are also classified as cargo. Aircraft operator security programs further define the terms ‘cargo’ and ‘non-U.S. Mail’.” Under TSA regulations, international mail destined for the United States is considered cargo and, as a result, is subject to all existing security controls. These security controls, which include screening for unauthorized explosive, incendiary, and other destructive substances or items in accordance with TSA regulations and security program requirements, are applied to international mail prior to transporting on aircraft at Last Point of Departure locations to the United States. These requirements are not dependent on advance electronic manifest data, as provided by ECC operators and other participants in the Air Cargo Advance Screening (ACAS) pilot program.
11 CBP offices involved in this assessment include OFO, the Office of Training and Development CBP Canine Training Program, the Laboratory and Scientific Services Directorate, and the Office of Chief Council, Labor Employee Relations, and Occupational Safety and Health Divisions.
12 Synthetic drugs seized in the mail environment generally contain a purity greater than 90 percent with the exception of two drug classes: naturally occurring drugs and certain forms of steroids. In contrast, the purity of seizures along the Southwest border, and particularly of synthetic opioids, average about seven percent controlled substance content. At limited land POEs, officers use Gemini Raman Spectroscopy and handheld narcotics analyzer equipment and NIK narcotic field drug test kits that have the ability to make identifications of illicit substances. However, detecting synthetic opioids that are mixed with cutting agents, such as lactose and dipyrone, which are regularly found at Southwest LPOEs, remain a challenge for the current technology.
13 Raman spectroscopy is a technique used in chemistry to provide a structural fingerprint by which molecules can be identified.
14 The NIK field presumptive test kits are chemical screening kits used to identify the most commonly encountered narcotic and street drugs.
15 LSSD has provided triage on 5,299 submissions during FY 2015, and 8,384 submissions for FY 2016. Since the inception of the program, LSSD has triaged 20,158 submissions within a business day and has generated many controlled deliveries because of the rapid turnaround.
16 Expedited analysis can have a turnaround time of a day or two; the turnaround time for non-expedited samples can be up to two months. Routine samples are treated as non-expedited. Samples that are treated as expedited are samples that are destined for controlled deliveries, have an impending court date, person or persons under arrest or detention, or are otherwise deemed a priority.
17 Phase 1 Naloxone Pilot Program POEs include El Paso; Laredo; Fort Lauderdale International Airport; John K. Kennedy International Airport; San Luis: San Ysidro; and Seattle/Blaine.
18 Phase 2 Naloxone Pilot Program POEs include Miami Int’l/Miami Seaport; Boston; Buffalo; Detroit; Newark; Chicago; Houston Int’l/Houston Seaport; and Dallas.

Information Sharing and Operational Coordination

Substantive and timely information sharing is critical to targeting and interdicting shipments containing illicit drugs. CBP contributes to the whole-of-government effort to identify and disrupt sophisticated routes and networks used by DTOs for the smuggling of illicit drugs by sharing critical information on individuals and cargo with investigative and intelligence partner agencies.

To bolster its targeting mission in the international mail and ECC environments, the NTC collaborates with critical partners on a daily basis, including ICE-HSI, the Drug Enforcement Administration (DEA), the Federal Bureau of Investigation, the Food and Drug Administration Office of Criminal Investigations (FDA/OCI), other members of the Intelligence Community, and the United States Postal Inspection Service (USPIS). CBP is sharing information with these agencies and conducting joint enforcement initiatives, including intelligence-driven operations designed to identify and disrupt drug smuggling. As of April 2017, the NTC has two permanent USPIS employees working in the NTC narcotic targeting units under a recent MOU. Moreover, NTC works in close coordination with several pertinent task forces including the Organized Crime Drug Enforcement Task Forces, the High Intensity Drug Trafficking Areas, as well as the Department of Homeland Security’s Joint Task Force–West and Joint Task Force–Investigations.

The OFO Tactical Operations Division directs special enforcement operations, in concert with ICE-HSI and other law enforcement partners, to identify and disrupt drug smuggling at targeted POEs, IMFs, and ECC facilities. These operations involve NII technology, canine enforcement teams, Antiterrorism-Contraband Enforcement Teams, Special Response Teams, and other law enforcement partner resources. For example, in January 2017, CBP officers at the John F. Kennedy (JFK) International Airport IMF partnered with ICE-HSI, DEA, FDA, U.S. Fish and Wildlife Service, and the U.S. Consumer Product Safety Commission to launch "Operation Mail Flex." This five-day joint operation targeted and interdicted illicit fentanyl and other opioids shipments that posed a health and safety risk to consumers. Operation Mail Flex focused on express mail originating in China and Hong Kong. This successful operation resulted in the seizure of 2.4 kilograms (5.31 pounds) of fentanyl and 134 other controlled substances. It also resulted in the seizure of 1,297 non-compliant imports and provided law enforcement officers with the opportunity to conduct eight controlled deliveries to unsuspecting drug smugglers. CBP is also conducting other special enforcement operations, including “Operation Crush” at the ECC facilities in Cincinnati, Louisville, and Memphis to seize hard narcotics such as fentanyl.

Additionally, CBP is a key partner in the implementation of the Office of National Drug Control Policy’s (ONDCP) Heroin Availability Reduction Plan (HARP). CBP also participates in the Department of Justice’s Nationwide Deconfliction System operated by DEA, conducting interagency deconfliction and coordination, and is the second most prolific user among all federal agencies. CBP is also working with the Heroin and Fentanyl Working Group at the DEA Special Operations Division, alongside ICE-HSI, and at the El Paso Intelligence Center to link drug seizures to international and domestic distribution networks.
Conclusion

There is no single entity or single solution that can stop the flow of dangerous illicit drugs into the United States or keep them from harming the American public. Tackling this complex threat involves a united, comprehensive strategy and an aggressive approach by multiple entities across all levels of government. With continued support from Congress, CBP, in coordination with our partners, will continue to refine and further enhance the effectiveness of our detection and interdiction capabilities to combat transnational threats and the entry of dangerous illicit drugs into the United States.

CBP will continue to work with our government and private-sector partners to improve the efficiency of information sharing and operational coordination to address the challenges and threats posed by illicit narcotic smuggling in the international mail environment. CBP, and specifically OFO, will also continue to work with USPS and USPIS to improve interdiction in the mail environment through improved advanced data, and other security best practices at the Nation’s IMFs.

Chairman Meadows, Ranking Member Connolly, and distinguished Members of the Subcommittee, thank you for the opportunity to testify today. I look forward to your questions.
5
Harm Reduction Resources / Re: Call 911!!!!
« Last post by Hooloovoo on October 07, 2017, 02:26:41 AM »
Who said I'm addicted?  :)
6
Harm Reduction Resources / Re: Call 911!!!!
« Last post by Vesp on October 07, 2017, 12:47:32 AM »
Just die already you degenerate junkie.
What the fuck is your problem zippy? we don't need  that kind of bollocks here.

Agree with Tsathoggua. Why hate anyone addicted?
7
Harm Reduction Resources / Re: Call 911!!!!
« Last post by Tsathoggua on October 06, 2017, 02:51:04 AM »
What the fuck is your problem zippy? we don't need  that kind of bollocks here.
8
Harm Reduction Resources / Re: Call 911!!!!
« Last post by Hooloovoo on October 06, 2017, 01:26:21 AM »
I'll get right on that.  :)
9
Harm Reduction Resources / Re: Call 911!!!!
« Last post by Zippy on October 06, 2017, 01:10:13 AM »
Just die already you degenerate junkie.
10
Harm Reduction Resources / Re: Call 911!!!!
« Last post by Hooloovoo on October 05, 2017, 11:48:50 PM »
Surprisingly enough, I have a snap-top glass ampoule containing 0.4mg Naloxone.  :)
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