INTERNATIONAL NARCOTICS CONTROL BOARD

Precursors
and chemicals frequently used in the illicit manufacture
of narcotic drugs and psychotropic substances

2019

EMBARGO
Observe release date:
Not to be published or broadcast before
Thursday, 27 February 2020, at 1100 hours (CET)
UNITED NATIONS CAUTION
 Reports published by the International Narcotics Control Board for 2019

The Report of the International Narcotics Control Board for 2019 (E/INCB/2019/1) is
supplemented by the following reports:

Narcotic Drugs: Estimated World Requirements for 2020—Statistics for 2018 (E/INCB/2019/2)

Psychotropic Substances: Statistics for 2018—Assessments of Annual Medical and Scientific

Requirements for Substances in Schedules II, III and IV of the Convention on Psychotropic
­Substances of 1971 (E/INCB/2019/3)

Precursors and Chemicals Frequently Used in the Illicit Manufacture of Narcotic Drugs and
­Psychotropic Substances: Report of the International Narcotics Control Board for 2019 on the
Implementation of Article 12 of the United Nations Convention against Illicit Traffic in Narcotic
Drugs and Psychotropic Substances of 1988 (E/INCB/2019/4)

The updated lists of substances under international control, comprising narcotic drugs,
­ sychotropic substances and substances frequently used in the illicit manufacture of narcotic drugs
p
and psychotropic substances, are contained in the latest editions of the annexes to the statistical
forms (“Yellow List”, “Green List” and “Red List”), which are also issued by the Board.

Contacting the International Narcotics Control Board

The secretariat of the Board may be reached at the following address:

Vienna International Centre
Room E-1339
P.O. Box 500
1400 Vienna
Austria

In addition, the following may be used to contact the secretariat:

Telephone: (+43-1) 26060
Fax: (+43-1) 26060-5867 or 26060-5868
Email: incb.secretariat@un.org

The text of the present report is also available on the website of the Board (www.incb.org).
 INTERNATIONAL NARCOTICS CONTROL BOARD

Precursors
and chemicals frequently used in the illicit
manufacture of narcotic drugs and
psychotropic substances
Report of the International Narcotics Control Board for 2019 on the
Implementation of article 12 of the United Nations Convention against
Illicit Traffic in Narcotic Drugs and Psychotropic Substances of 1988

UNITED NATIONS
Vienna, 2020
 E/INCB/2019/4

UNITED NATIONS PUBLICATION

Sales No. E.20.XI.2
ISBN: 978-92-1-148339-0
eISBN: 978-92-1-004846-0
ISSN 2411-8664
eISSN 2411-8672

© United Nations: International Narcotics Control Board, January 2020. All rights reserved worldwide.
Publishing production: English, Publishing and Library Section, United Nations Office at Vienna.
Foreword
It is my sincere pleasure to introduce the report on precursors for 2019 of the International Narcotics
Control Board (INCB). The annual report on precursors has established itself over the years as a
­reference for professionals and government authorities in monitoring and analysing the latest trends
in precursor control, but also as a practical tool for addressing emerging challenges.

In the three decades since the adoption of the United Nations Convention against Illicit Traffic in
Narcotic Drugs and Psychotropic Substances of 1988, the global landscape of drugs has indeed
changed significantly. Governments around the world are increasingly concerned about the misuse of
non-scheduled precursors used in the manufacture of dangerous substances. Today, designer precur-
sors of synthetically engineered and harmful drugs are made on demand and easily ordered online.

Given the diversity and almost infinite number of substances that could possibly be made, traditional
scheduling, both nationally and internationally, represents the minimum among measures needed.
Governments need to design new tools to address these continuously changing trends. To that end,
this year’s report highlights the possibilities offered under article 13 of the 1988 Convention, as a
­complementary tool in the fight against illicit drug manufacture.

Furthermore, through its global initiatives Project Cohesion and Project Prism, INCB has been suc-
cessful for many years in facilitating operational cooperation, both bilateral and multilateral, among
Member States to counter the diversion of and trafficking in precursors.

To effectively respond to the complex landscape of drug control matters, INCB has both developed
and expanded practical and innovative partnerships. With the committed support of Governments,
INCB is encouraging public-private partnerships in various industries to counter diversion and traf-
ficking. A core element of the Board’s approach is the provision of online communication platforms,
such as the Precursors Incident Communication System (PICS), for the sharing of information and
intelligence in real time.

I would like to thank Governments for supporting the Board’s activities in the area of precursor
control.

Cornelis P. de Joncheere
President of the International
Narcotics Control Board

iii
Preface
The United Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances
of 1988 requires the International Narcotics Control Board to report annually to the Commission on
Narcotic Drugs on the implementation of article 12 of the Convention and requires the Commission
to periodically review the adequacy and propriety of Tables I and II of the Convention.

In addition to its annual report and other technical publications on narcotic drugs and psychotropic
substances, the Board has prepared its report on the implementation of article 12 of the 1988 Convention
in accordance with the following provisions, contained in article 23 of the Convention:

1. The Board shall prepare an annual report on its work containing an analysis of the information at
its disposal and, in appropriate cases, an account of the explanations, if any, given by or required of
parties, together with any observations and recommendations which the Board desires to make. The
Board may make such additional reports as it considers necessary. The reports shall be submitted to
the Economic and Social Council through the Commission, which may make such comments as it
sees fit.

2. The reports of the Board shall be communicated to the parties and subsequently published by the
Secretary-General. The parties shall permit their unrestricted distribution.

v
Contents
Page
Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii
Preface . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v
Explanatory notes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xi
Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xiii
Chapter

I. Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

II. Action taken by Governments and the International Narcotics Control Board . . . . . . . . . . . . . . . . . . . . 1
A. Scope of control. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
B. Adherence to the 1988 Convention. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
C. Reporting to the Board pursuant to article 12 of the 1988 Convention. . . . . . . . . . . . . . . . . . . . . . . 2
D. Legislation and control measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
E. Submission of data on licit trade in, uses of and requirements for precursors. . . . . . . . . . . . . . . . . 6
F. Annual legitimate requirements for imports of precursors of amphetamine-type stimulants. . . . . 7
G. Pre-export notifications and utilization of the Pre-Export Notification Online system . . . . . . . . . 8
H. Other activities and achievements in international precursor control . . . . . . . . . . . . . . . . . . . . . . . . 11

III. Extent of licit trade and latest trends in trafficking in precursors. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

A. Substances used in the illicit manufacture of amphetamine-type stimulants. . . . . . . . . . . . . . . . . . . 13
B. Substances used in the illicit manufacture of cocaine. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
C. Substances used in the illicit manufacture of heroin . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
D. Substances used in the illicit manufacture of other narcotic drugs and psychotropic
substances. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
E. Substances not listed in Table I or Table II of the 1988 Convention that are used in the
illicit manufacture of other narcotic drugs and psychotropic substances or substances of
abuse not under international control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

IV. Article 13 of the 1988 Convention as a complementary tool in addressing illicit drug
manufacture. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40

Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

Annexes*
I. Parties and non-parties to the United Nations Convention against Illicit Traffic
in Narcotic Drugs and Psychotropic Substances of 1988, by region, as at 1 November 2019. . . . . . . . 45
II. Submission of information by Governments pursuant to article 12 of the United Nations
Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances of 1988
(form D) for the period 2014–2018. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50
III. Seizures of substances in Tables I and II of the United Nations Convention against
Illicit Traffic in Narcotic Drugs and Psychotropic Substances of 1988, as reported to
the International Narcotics Control Board, 2014–2018. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56
IV. Submission of information by Governments on licit trade in, legitimate uses of and requirements
for substances in Tables I and II of the United Nations Convention against Illicit Traffic
in Narcotic Drugs and Psychotropic Substances of 1988 for the years 2014–2018. . . . . . . . . . . . . . . . . . 83

* The annexes are not included in the printed version of the present report but are available on the website of the International Narcotics Control
Board (www.incb.org).

vii
 V. Annual legitimate requirements for ephedrine, pseudoephedrine, 3,4-methylenedioxyphenyl-2-
propanone and 1-phenyl-2-propanone; substances frequently used in the manufacture
of amphetamine-type stimulants. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 90
VI. Governments that have requested pre-export notifications pursuant to article 12,
subparagraph 10 (a), of the United Nations Convention against Illicit Traffic in
Narcotic Drugs and Psychotropic Substances of 1988. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 97
VII. Substances in Tables I and II of the United Nations Convention against Illicit Traffic
in Narcotic Drugs and Psychotropic Substances of 1988. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 101
VIII. Use of scheduled substances in the illicit manufacture of narcotic drugs and
psychotropic substances. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 102
IX. Licit uses of the substances in Tables I and II of the United Nations Convention
against Illicit Traffic in Narcotic Drugs and Psychotropic Substances of 1988 . . . . . . . . . . . . . . . . . . . . . 106
X. Treaty provisions for the control of substances frequently used in the illicit manufacture
of narcotic drugs and psychotropic substances. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108
XI. Regional groupings. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109

Figures
I. Percentage of States parties that have not yet provided, pursuant to Commission on Narcotic
Drugs resolution 49/3, any estimated annual legitimate requirements for precursors of
amphetamine-type stimulants, by region, 2019 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
II. Percentage of countries that invoked article 12, subparagraph 10 (a), of the 1988 Convention,
by region, 2019. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
III. Preparations containing pseudoephedrine notified through the PEN Online system for export to Iraq,
2015–2019. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
IV. Imports of pseudoephedrine into the Sudan and Yemen notified by exporting countries through
the PEN Online system, 2014–2019. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
V. Methamphetamine laboratories dismantled in Nigeria, 2011–2019. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
VI. Proposed imports of ephedrines into Nigeria and corresponding estimated annual legitimate
requirements, 2015–2019. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
VII. Proposed imports of ephedrines into Ghana and corresponding estimated annual legitimate
requirements, 2015–2019. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
VIII. Global seizures of P-2-P reported on form D, 2009–2018. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
IX. Incidents involving APAAN, APAA, MAPA and P-2-P methyl glycidic acid derivatives
communicated through the Precursors Incident Communication System, 2012–2019 . . . . . . . . . . . . . . 23
X. Seizures of APAA, MAPA and P-2-P methyl glycidic acid derivatives communicated by countries
in Europe through the Precursors Incident Communication System, in kilograms, 2019 . . . . . . . . . . . 24
XI. Methods used in the illicit manufacture of methamphetamine, as determined by the forensic profiling
of methamphetamine samples from the United States of America and Mexico, 2015–2018. . . . . . . . . . . . 24
XII. Seizures of substitutes of 3,4-MDP-2-P communicated through the Precursors Incident
Communication System, 2013–2019. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
XIII. Seizures of acetic anhydride reported by States members of the European Union on
form D, 2011–2018. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
XIV. Schematic overview of illicitly manufactured tablets, by drug and region. . . . . . . . . . . . . . . . . . . . . . . . . 41
XV. Seizures of tableting machines in Australia, 2008–2018. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
XVI. Seizures of tableting machines by the United States Customs and Border Protection,
2014–2019. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

viii
Maps
1. Submissions of form D for 2018 (as at 1 November 2019). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
2. Use of the PEN Online system, by percentage of pre-export notifications viewed, 2019. . . . . . . . . . . . 10

Boxes
1. Risk factors for diversion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
2. Examples of ongoing investigations into diversion attempts involving acetic anhydride. . . . . . . . . . . . . 31
3. Investigations into the suspected misuse of online trading platforms by traffickers. . . . . . . . . . . . . . . . . 34
4. Proof of intent and knowledge in precursor-related crime . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
5. Article 13 of the 1988 Convention. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

Table
The 10 largest importers and exporters of ephedrines, by volume, 2016–2018 . . . . . . . . . . . . . . . . . . . . . . . . . 14

ix
Explanatory notes
The boundaries and names shown and the designations used on the maps in the present publication
do not imply official endorsement or acceptance by the United Nations.

The designations employed and the presentation of the material in the present publication do not
imply the expression of any opinion whatsoever on the part of the Secretariat of the United Nations
concerning the legal status of any country, territory, city or area or of its authorities, or concerning the
delimitation of its frontiers or boundaries.

Countries and areas are referred to by the names that were in official use at the time the relevant data
were collected.

Multiple government sources of data were used to generate the present report, including form D
­(information on substances frequently used in the illicit manufacture of narcotic drugs and ­psychotropic
substances); the Pre-Export Notification Online (PEN Online) system; the Precursors Incident
Communication System (PICS); results achieved under Project Prism and Project Cohesion, which are
the international operational initiatives regarding chemicals used in the illicit manufacture of, respec-
tively, synthetic drugs, and cocaine and heroin; and official communications with competent national
authorities and official national reports on the drug and precursor control situation.

Unless otherwise specified, data provided on form D are referred to by the calendar year to which they
apply; the cut-off date for reporting the data is 30 June of the following year. The reporting period for
data from the PEN Online system and PICS is from 1 November 2018 to 1 November 2019, unless
otherwise specified. Where PEN Online system data are used for multiple years, calendar years are
used. Additional information was provided through regional and international partner organizations,
as indicated in the report.

With regard to data on seizures, readers should bear in mind that reported seizures generally reflect
the corresponding level of regulatory and law enforcement activity at that specific time. In addition, as
seizures are often the result of law enforcement cooperation among several countries (e.g., through
controlled deliveries), the occurrence of seizures and the volumes seized in a given country should not
be misinterpreted or used as an overestimation in assessing that country’s role in the overall situation
of trafficking in precursors.

Reference to “tons” is to metric tons, unless otherwise stated.

The following abbreviations have been used in the present report:

ANPP 4-anilino-N-phenethylpiperidine
4-AP 4-anilinopiperidine (N-phenylpiperidin-4-amine)
APAA alpha-phenylacetoacetamide (2-phenylacetoacetamide)
APAAN alpha-phenylacetoacetonitrile
GBL gamma-butyrolactone
GHB gamma-hydroxybutyric acid
MAPA  methyl alpha-phenylacetoacetate (methyl
3-oxo-2-phenylbutanoate)
MDMA 3,4-methylenedioxymethamphetamine
3,4-MDP-2-P 3,4-methylenedioxyphenyl-2-propanone
3,4-MDP-2-P methyl glycidate methyl ester of 3,4-MDP-2-P methyl glycidic acid
NPP N-phenethyl-4-piperidone
P-2-P 1-phenyl-2-propanone
PEN Online system Pre-Export Notification Online system
PICS Precursors Incident Communication System

xi
Summary
In 2019, the year set as the target date in the Political Declaration and Plan of Action on International
Cooperation towards an Integrated and Balanced Strategy to Counter the World Drug Problem of
2009, the international community took stock of the achievements and remaining challenges in
addressing the world drug problem, including in the area of precursor control. With the accession of
Palau as the 190th State party to the United Nations Convention against Illicit Traffic in Narcotic Drugs
and Psychotropic Substances of 1988, adherence to that Convention is now nearly universal. A total of
164 countries and territories are using the International Narcotics Control Board’s online pre-export
notification system to cooperate in the monitoring of international trade in controlled precursors, and
a number of countries have strengthened their legislation or introduced other practical measures to
monitor the movement of chemicals both in international trade and domestic distribution.

However, trafficking attempts continue to be identified in all regions of the world, involving chemicals
under international control, such as acetic anhydride, as well as chemicals not controlled i­ nternationally.
Trafficking trends observed in the period 2018–2019 provided further evidence of the illicit manufac-
ture of amphetamine-type stimulants in regions and countries not previously associated with such
manufacture. This included evidence of the large-scale illicit synthesis of amphetamine, the active
ingredient in “captagon” tablets, from non-scheduled pre-precursors in the Middle East; the illicit
manufacture of methamphetamine in Afghanistan from ephedra growing wild in the mountainous
regions of that country; and illicit methamphetamine manufacture in Europe, using the same manu-
facturing methods as for amphetamine, as well as ephedrines-based methods. Information available
to the Board also suggests that organized criminal groups in Mexico have turned to another, new
method to synthesize methamphetamine from non-scheduled chemicals.

For chemicals used in the illicit manufacture of heroin, namely acetic anhydride, not many new cases of
diversion were identified in 2018, although the amount seized globally remained relatively high. The
Board actively facilitated a number of ongoing investigations into suspicious transactions and seizures
involving acetic anhydride that have been identified since 2016. As a result, links between what
appeared to be isolated cases were identified, suggesting a much larger network of criminal activities
than previously thought. The main source of potassium permanganate, the key chemical used in the
illicit manufacture of cocaine, continued to be domestic diversion, i.e., diversion within the country of
final use, or within the region, with subsequent smuggling into the country of final use. Colombia also
continued to report the illicit manufacture of potassium permanganate. Other c­ hemicals used for illicit
cocaine processing were typically diverted from domestic sources.

Since 2018, and just over a year after NPP and ANPP were placed under international control under
the 1988 Convention, traffickers have started to seek alternatives to the two precursors of fentanyl and
a few of its analogues. This has included the use of alternative manufacturing methods that do not
require the two precursor chemicals and the use of non-scheduled pre-precursors. Trafficking trends
are difficult to discern because of the potency of the end products and the correspondingly small size
of precursor consignments. In response to these developments, which follow the pattern observed
among other controlled precursors, some countries have strengthened national controls on fentanyl
precursors. Several of these controls have been generic in nature, a development that the Board
acknowledges, given the rapid evolution of precursors, including the increased availability of designer
precursors with no known, or very limited, legitimate uses. To facilitate the work of competent regula-
tory and enforcement authorities, the Board has amended its limited international special surveillance
list of non-scheduled chemicals to include additional fentanyl precursors and has highlighted those
for which it is not aware of any legitimate uses.

The proliferation of non-scheduled chemicals, including designer precursors and other series of
closely related chemicals, remains an issue of concern to the Board and requires a wider policy
­discussion about the options available to ensure that there is a common global framework within

xiii
 which authorities can cooperate effectively to prevent such chemicals from reaching illicit
­laboratories. This policy discussion must continue, in particular in the light of recent developments
related to ­fentanyl precursors.

At the same time, the Board’s observations related to diversion attempts and cases of diversion and
seizures of precursors under international control suggest that the existing legal framework may need
to be enforced more rigorously at the national level and/or that Governments should explore practical
ways of addressing evidentiary challenges associated with proving instances of precursor-related
crime. Observations made during the reporting period have also shown that voluntary cooperation
between Governments and different sectors of industry beyond the manufacturing industries is a
­valuable complement to any regulatory framework.

From the Board’s perspective, the least satisfactory elements in its cooperation with Governments on
precursor-related matters in the period 2018–2019 were the level of reporting through form D, in
particular the timeliness of the reports received and their quality and comprehensiveness, especially in
relation to the suspected origin or point of diversion of seized chemicals. This has limited the ability of
the Board and Governments alike to analyse and address weaknesses in existing control measures in a
timely manner, although improved information-sharing through PICS and improved case ­cooperation,
in particular in relation to acetic anhydride, have partly offset the reporting limitations.

A new area of engagement for the Board is essential equipment used in illicit drug manufacture.
Specifically, and in the light of the increased sophistication of the illicit manufacture of drugs, new
psychoactive substances and pre-precursors, activities in this area are aimed at developing effective
cooperation mechanisms to prevent and investigate the diversion of equipment in the context of
­article 13 of the 1988 Convention.

xiv
I. Introduction II. Action taken by
Governments and
1. The present report summarizes the action taken by
Governments and by the International Narcotics Control the International
Board (INCB), since the publication of the 2018 report on
precursors,1 to prevent chemical diversion and implement
Narcotics Control
the provisions of the United Nations Convention against
Illicit Traffic in Narcotic Drugs and Psychotropic Substances
Board
of 1988.
A. Scope of control
2. Chapter II begins with an account of the activities
6. The responsibilities of the Board under article 12 of
­carried out during the reporting period with regard to the
the 1988 Convention include the assessment of ­substances
scheduling of substances. The remainder of chapter II con-
for possible inclusion in Table I or Table II, or for resched-
tains statistical data and other information on action taken
uling from one table to another, of the Convention.
by Governments and the status of implementation of the
Furthermore, in accordance with article 12, paragraph 2,
tools and mechanisms provided or coordinated by the
of the 1988 Convention, if a party or the Board has any
Board to assist Governments in implementing the ­provisions
information which, in its opinion, may require the sched-
of article 12 of the 1988 Convention.
uling or rescheduling of a ­substance in Table I or Table II,
it should notify the Secretary-General and furnish him
3. Chapter III provides an overview of the major trends
with the ­information in support of that notification.
and developments in licit trade and trafficking in and illicit
use of individual chemicals. It contains a summary of
seizures, cases of suspicious and stopped shipments,
­
Inclusion of three precursors of
­diversions or attempted diversions, and activities associated amphetamine-type stimulants in Table I
with illicit drug manufacture. of the 1988 Convention
7. On 19 March 2019, the Commission on Narcotic Drugs
4. As has been the practice since 2011, one precursor-
decided, in accordance with the Board’s recommendation, to
related theme is addressed in greater depth in the report.
add three precursors of amphetamine-type stimulants to
In this year’s report, the theme explored in chapter IV is
Table I of the 1988 Convention and not to include hydriodic
article 13 of the 1988 Convention as a complementary tool
acid in the tables of that Convention. The three substances
in addressing illicit drug manufacture. Throughout the
added to Table I of the 1988 Convention were APAA, 3,4-MDP-
report, specific recommendations and conclusions are
2-P methyl glycidic acid, and 3,4-MDP-2-P methyl glycidate,
highlighted to facilitate the taking of specific actions by
the methyl ester of 3,4-MDP-2-P methyl glycidic acid.
Governments to prevent diversion.2
8. As no request to review the decisions of the
5. Annexes I to XI contain updated statistics and p­ ractical Commission was submitted to the Economic and Social
information for use by competent national authorities. The Council, the scheduling decisions became fully effective
annexes are not included in the printed copies of the on 19 November 2019, 180 days after being communicated
­present report but are available on the INCB website. by the Secretary-General to the parties. INCB has updated
the relevant documentation, including form D and the red
list, with information about the three newly scheduled
chemicals. The updated documents are available on the
website of the Board (www.incb.org).

9. The Board urges all Governments to introduce the

required controls as soon as possible and to inform it
accordingly. The Board wishes to remind all Governments
1
E/INCB/2018/4.
that pre-export notifications, as ­ provided for under
2
A compilation of the recommendations relating to international
precursor control made by INCB in previous years is available on the article 12, subparagraph 10 (a), now apply to any
­
Board’s website (www.incb.org). ­transactions in international trade in the three chemicals.

1
2   INCB REPORT ON PRECURSORS 2019

Recommendation to include MAPA in Oceania (Kiribati, Papua New Guinea, Solomon Islands
and Tuvalu) that are not yet parties to the Convention to
Table I of the 1988 Convention
implement the provisions of article 12 and to become
10. Pursuant to its responsibilities under article 12 of the ­parties to the Convention without further delay.
1988 Convention, INCB also carried out the following
activities in 2019:
C. Reporting to the Board
(a) It submitted a notification to the Secretary-General
in May 2019, informing him that it had i­nformation at its
pursuant to article 12 of the
­disposal suggesting the potential need to include MAPA, yet 1988 Convention
another designer precursor suitable for the illicit manufacture
14. Under article 12, paragraph 12, of the 1988
of P-2-P and subsequently amphetamine and methampheta-
Convention, parties are required to submit annually to
mine, in Table I or Table II of the 1988 Convention;
INCB information on: (a) the amounts seized of s­ ubstances
(b) It concluded its assessment of MAPA in included in Tables I and II of that Convention and, when
November 2019 and submitted its scheduling recommen- known, their origin; (b) any substance not included in
dation to the Commission on Narcotic Drugs for Table I or Table II that is identified as having been used in
­consideration at its sixty-third session, in March 2020. the illicit manufacture of narcotic drugs or psychotropic
substances; and (c) methods of diversion and illicit manu-
11. MAPA is chemically related to APAA and incidents of facture. Parties are required to submit the information on
its use in illicit manufacture have been reported, in particu- the form, known as form D, made available by INCB.4 The
lar after the scheduling process for APAA was initiated, in deadline for submission of the 2018 data was 30 June 2019,
late 2017. Similar to APAA, APAAN and other designer although INCB continued to encourage earlier submission
precursors, MAPA does not have any known legitimate use (by 30 April) to allow sufficient time for any necessary
and is therefore not traded widely and regularly, although it clarification of the information received.
is advertised by a number of online suppliers.
15. As at 1 November 2019, a total of 126 countries and
12. As with other recently scheduled precursors, MAPA territories had submitted form D for 2018, up from 62 as at
does not currently have a unique Harmonized System (HS) 30 June 2019. Both the submission rate as at 30 June and the
code.3 Nevertheless, if traded legitimately, the applicable HS rate as at the end of the reporting cycle were among the
group code should be used, otherwise any shipment lowest in recent years. Gabon submitted form D for the first
­containing MAPA could be considered misdeclared (HS time. INCB welcomes the fact that, of the States parties that
classifications of non-scheduled chemicals used in the illicit had failed to submit form D for five years or more, Mauritius,
manufacture of drugs are available to competent national North Macedonia, Sierra Leone, Suriname and Yemen have
authorities on a secure page of the INCB website). INCB resumed doing so. Nevertheless, 66 States parties to the
works with the World Customs Organization to establish 1988 Convention failed to submit form D for 2018. Of those,
unique HS codes. Until such time as MAPA is assigned a 32 have not done so for the past five years (see map 1). Viet
unique HS code, INCB recommends that Governments Nam submitted form D for both the previous reporting
adopt, on a voluntary basis, interim, d ­ iscrete codes based cycle (calendar year 2017) and the current reporting cycle.
on Harmonized System nomenclature. Comprehensive information about the submission of
form D by all Governments is included in annex II.

16. In 2019, the Board’s analysis of the global precursor

B. Adherence to the
situation continued to be affected by the low rate of submis-
1988 Convention sion of form D, late submission, the submission of ­incomplete
or entirely blank forms, and the inability of certain
13. As at 1 November 2019, following the accession of Palau
Governments to gather information at the national level and
on 14 August 2019, the 1988 Convention had been ratified,
consolidate it in a single form. INCB reiterates its call to
acceded to or approved by 190 States and formally confirmed
Governments to submit form D on time and to make
by the European Union (extent of competence: article 12).
every effort to confirm and provide details of seizures in a
Details on the status of accession by region are provided in
timely manner, when so requested by the Board.
annex I. The Board urges the remaining States in Africa
(Equatorial Guinea, Somalia and South Sudan) and 4
For the 2018 reporting cycle, INCB introduced an Excel form in an
effort to streamline and expedite the reporting process and to minimize
3
See World Customs Organization, Harmonized Commodity the potential for data entry errors. The latest version of form D is available
Description and Coding System, 6th ed. (Brussels, 2017). on the INCB website in the six official languages of the United Nations.
Map 1. Submissions of form D for 2018 (as at 1 November 2019)
II.

Hong Kong,
Kong,SAR
SARof China
Macao, SAR of China

Submitted form D by the

deadline
Submitted form D after the
deadline

Failed to submit form D for 2018

Failed to submit form D for any year

during the period 2014-2018 The boundaries and names shown and the designations used on this map do not imply official endorsement or acceptance by the United Nations.
Final boundary between the Sudan and South Sudan has not yet been determined. Dotted line represents approximately the Line of Control
in Jammu and Kashmir agreed upon by India and Pakistan. The final status of Jammu and Kashmir has not yet been agreed upon by the parties.
A dispute exists between the Governments of Argentina and the United Kingdom of Great Britain and Northern Ireland concerning
sovereignty over the Falkland Islands (Malvinas).

Note: See also annex II.

Action taken by Governments and the International Narcotics Control Board   3
4   INCB REPORT ON PRECURSORS 2019

17. With regard to the seizures of substances listed in series of 2018, on the drafting of guidelines to enhance the
Tables I and II of the 1988 Convention that were effected in control and monitoring of new psychoactive substances
2018, 73 Governments reported mandatory ­information and of chemicals considered as substitutes for substances
on the amounts seized (for details on the reported seizures listed in Tables I and II of the 1988 Convention.
by region, see annex III). Information on the origin of
seized substances was rarely provided, although such infor- 20. In December 2018, the Government of Mexico
mation is critical for identifying emerging trends and initi- reduced the thresholds for domestic distribution of and
ating backtracking investigations. In addition, only a few of international trade (import and export) in acetic ­anhydride
the submitting Governments supplemented their reports and potassium permanganate, from 1,000 kg to 1 kg.
with the additional information required on: (a) seizures of
substances not included in Tables I and II and identified as 21. As part of efforts to ensure that drug policy is based
having been used in illicit drug manufacture; (b) methods on scientific evidence, the Government of Mexico began
of diversion and illicit manufacture; and (c) stopped ship- implementing a drug profiling programme to help
ments. More often, the information provided was presented ­determine trends in illicit drug manufacture and the pre-
in the form of aggregated figures and did not provide cursors used. Initial results included the identification of a
­sufficient details to enable the Board to identify new and non-scheduled pre-precursor of fentanyl (see also para. 60)
emerging trends in illicit drug manufacture and trafficking and the finding that the same method of synthesis identi-
in precursors. INCB regrets that, as in the past, only fied in 2009 was still being used for the illicit manufacture
50 Governments (or 40 per cent of the 126 submitting of methamphetamine.
Governments) provided the required information on sei-
zures of substances not listed in Table I or Table II, and only 22. In April 2019, Serbia amended its existing legislation
28 Governments (or 22 per cent) provided information on on precursors. In the same year, the Government also
methods of diversion and illicit manufacture. INCB com- passed a comprehensive set of bylaws concerning precursor
mends those Governments that provided the required control-related procedures, including on licensing, import
information and urges all other Governments to make and export authorizations, and statements ­concerning the
every effort to collect and report complete information end user of a traded precursor.
as mandated in article 12, paragraph 12, of the
Convention. Only through the sharing of such informa- 23. Effective 1 May 2019, China introduced the group
tion can emerging trends in trafficking in precursors be scheduling of fentanyl-related substances. Unlike similar
determined and the underlying weaknesses in control group definitions for fentanyl-related substances in the
systems be identified and successfully addressed. That ­legislation of other countries, the Chinese legislation also
knowledge, in turn, is essential for preventing future covers a group of substances that could be used as p
­ recursors
diversions worldwide. of fentanyls (i.e., the group of benzylfentanyls).

24. In May 2019, the Government of Canada placed three

D. Legislation and control measures precursors of fentanyl and fentanyl analogues (ANPP, NPP
and benzylfentanyl) under national control. All three pre-
18. Establishing and strengthening appropriate national cursors were listed under an extended scope of control that
control measures constitutes the basis for effective monitor- also included their derivatives and analogues and the salts
ing of the movement of precursors both in international of those derivatives and analogues. At the same time, the
trade and domestic distribution. Although there is no Government extended the scope of control in a similar
­reporting requirement to the Board in this regard, since manner for several precursors already listed in the relevant
1 November 2018, the following changes in control m ­ easures schedules of the Controlled Drugs and Substances Act of
have come to the attention of INCB. Canada. This applied to ­3,4-MDP-2-P and P-2-P, both of
which are precursors of amphetamine-type stimulants, and
19. Following seizures of chloroephedrine in the to norfentanyl.
Philippines in 2016, in January 2018, the Dangerous Drugs
Board of the Philippines amended the regulations 25. The Government of the Netherlands was in the
­concerning ephedrine and pseudoephedrine by including ­process of amending the Abuse of Chemical Substances
the isomers and salts of isomers of the two substances, as Act. Specifically, this involved the compilation of a list of
well as their halogenated and alkylated forms, and reclas- chemicals that are not included in Regulation (EC)
sifying all those forms and any preparations containing No. 273/2004 of the European Parliament and of the
them as dangerous drugs. Furthermore, in February 2018, European Council, and European Council Regulation
the Dangerous Drugs Board issued Board resolution No. 5, (EC) No. 111/2005, and that can be easily converted into a
 II. Action taken by Governments and the International Narcotics Control Board   5

drug or drug precursor and for which no legitimate sources of chemicals used in illicit cocaine processing. The
­industrial uses are known, with a view to prohibiting the results show that the supply of such chemicals is mainly
possession or transport of such chemicals without a fed by diversion from legitimate domestic industry or by
permit. The bill amending the Abuse of Chemical illicit manufacture. The Government has identified a
Substances Act was expected to be sent to parliament at number of priority actions that are to be pursued over the
the end of 2019. The Board welcomes the approaches next few years. They include enhancing public-private
taken by Canada and the Netherlands as means to pro- partnerships, investing in financial intelligence, enhancing
actively address the proliferation of chemicals used in national cooperation, in particular between regulatory
illicit drug manufacture. The Board invites both and customs authorities, and a greater focus on regulating
Governments to carefully monitor the implementation transport, foreign trade activities and the obtaining of
of the measures and to share relevant experiences with it ­natural resources that constitute fundamental chemical
so as to encourage other Governments to consider inputs, as well as interventions at the level of national
­similar innovative and proactive approaches. movements of controlled substances, so as to prevent
chemical precursors from reaching the main illicit manu-
26. The European Union was in the process of amending facturing areas, including by using real-time mapping
its precursor legislation by adding a number of designer mechanisms. The Board welcomes these activities and
precursors to its category 1 list of chemicals. In addition to encourages the Government of Colombia to share rele-
the chemicals that the Commission on Narcotic Drugs vant findings, lessons learned and successful approaches
decided to add to Table I of the 1988 Convention, and with the Board and through other existing cooperation
MAPA, which the Board recommended to be placed under mechanisms, such as the Inter-American Drug Abuse
international control in November 2019 (see paras. 7–12), Control Commission, so as to support similar action by
this also included two additional precursors of ampheta- other countries concerned.
mine and methamphetamine, namely, P-2-P methyl
­glycidic acid and its methyl ester. The amended legislation 31. In accordance with resolution 1992/29 of the
was expected to enter into force in the first half of 2020. The
Economic and Social Council, the Board compiles infor-
Board welcomes the scheduling of derivatives of P-2-P mation on the systems of authorization that Governments
methyl glycidic acid in Europe, the region most affected apply to the import and export of the substances listed in
by their illicit use, and will closely examine the impact ofTables I and II of the 1988 Convention, as well as on
this regional scheduling on the extent of use of these ­control measures applied to additional chemicals under
chemicals in the manufacture of illicit a­ mphetamine and national control. Competent national authorities can
methamphetamine, with a view to determining whether access this information on the Board’s secure website. To
there is still a need for global action. ensure that the INCB information is up to date at all times,
INCB encourages all Governments to inform it regu-
27. In response to encountering new fentanyl pre-­ larly of r­elevant changes to their national p ­ recursor
precursors (see para. 219), the Government of the United legislation.
States of America initiated a process to nationally control
such chemicals, namely 4-AP, including some of its “chem-
ically protected” derivatives, as well as benzylfentanyl and Measures at the international level
norfentanyl. to address the proliferation of ­­
non-scheduled chemicals, including
28. Effective 26 November 2019, by its Decree No. 593/2019,
designer precursors
Argentina improved the administrative controls related to the
licit use of precursors and updated the list of chemicals under 32. In its 2018 report on precursors, the Board drew
national control. Butyl alcohol and sodium nitrite, which can attention to the need to address the proliferation of
be used for the illicit manufacture of alkylnitrite inhalants, non-scheduled chemicals and designer precursors that are
were placed under surveillance. chemically closely related with each other and with a con-
trolled chemical. The Board noted that many of these
29. The Inter-American Drug Abuse Control Commission chemicals have no known legitimate use and are often
amended its model legislation in November 2019 to, inter designed specifically to circumvent existing legislation.
alia, address non-scheduled chemicals, including designer
precursors. 33. To advance the discussion and assist Governments in
preventing designer precursors from reaching illicit
30. Over the last few years, the Government of Colombia ­laboratories, in 2019, the Board conducted the activities
conducted a series of technical studies to shed light on the described below.
6   INCB REPORT ON PRECURSORS 2019

Limited international special surveillance list 37. It is clear that emerging chemicals that are not under
of non-scheduled substances national control pose challenges for Governments. The
challenges range from limitations on the extent to which
34. The limited international special surveillance list of
such cases can be investigated and the type of sanctions that
non-scheduled substances was updated to include a
can be applied, to difficulties in identifying and e­ stablishing
non-scheduled fentanyl pre-precursor and two non-­
­
voluntary cooperation mechanisms with r­ elevant operating
scheduled precursors of amphetamine-type stimulants,
partners and companies. INCB therefore encourages all
expand on the extended (“generic”) definitions that c­ apture
Governments to share successful national approaches to
derivatives, intermediates and other chemicals closely
addressing the challenges associated with non-scheduled
related to controlled precursors, and provide examples of
chemicals and designer precursors.
chemicals already being used in the illicit ­manufacture of
amphetamine-type stimulants, fentanyl and fentanyl-
­
related s­ ubstances. In addition, the updated list highlights
E. Submission of data on licit trade
those chemicals which do not have any known legitimate
uses. The updated list is included as part of the information in, uses of and requirements for
package on precursor control a­vailable on the Board’s precursors
secure website. INCB encourages c­ompetent national
authorities to make full use of the international special 38. In accordance with Economic and Social Council
surveillance list and alert relevant sectors of industry to resolution 1995/20, INCB requests Governments to
the possible misuse in illicit drug manufacture of ­voluntarily provide data on licit trade in, uses of and
­chemicals on the list. requirements for substances listed in Tables I and II of the
1988 Convention. Such data greatly enhance the ability of
INCB and Governments to understand the underlying
Policy discussion during the sixty-second
patterns of regular trade, identify suspicious activity and
session of the Commission on Narcotic Drugs prevent diversion.
35. In response to the Board’s call for a policy d ­ iscussion
on options to address the proliferation of n ­ on-scheduled 39. As at 1 November 2019, the Governments of 115 coun-
chemicals and designer precursors at the international tries and territories had submitted data on the licit
level, the Commission on Narcotic Drugs, at its sixty-­ ­movement of substances included in Table I or Table II of
second session, devoted some time to the subject. the 1988 Convention and 109 Governments had furnished
Following an opening statement by the President of data on the licit uses of and/or requirements for one or more
INCB, speakers shared information on domestic of those substances (see annex IV). The total figures for both
approaches and expressed their agreement with the data sets are lower than in previous years. INCB wishes to
Board’s assessment of the situation and the need for a thank all Governments that furnished data on the licit
broader discussion. As a result, an item on the topic will movement of substances included in Table I or Table II of
be on the agenda for subsequent s­essions of the the 1988 Convention, which provide the Board with a
Commission, starting in March 2020. means to identify weaknesses in precursor control and
international cooperation to that end.
Circular letter: measures to address the use
of non-scheduled chemicals in illicit drug 40. For example, according to information on licit trade
provided on form D for 2018, the Governments of China,
manufacture
Ecuador, Myanmar, Nigeria, the Republic of Korea and the
36. In March 2019, a circular letter was sent to all United States – each of which requires pre-export
Governments to enquire about the different national ­notification for shipments of acetic anhydride – reported
approaches and regulatory and law enforcement meas- having received shipments of acetic anhydride from China,
ures that are currently being taken to address the use of India, the Republic of Korea, Saudi Arabia and/or
non-scheduled chemicals in illicit drug manufacture,
­ Thailand.5 However, those shipments were not pre-­notified
including their level of implementation and related chal- by means of the PEN Online system by the authorities of
lenges, experiences and lessons learned. The Board would the respective exporting countries, making it difficult to
like to acknowledge the responses of 62 Governments monitor the supply chain. In addition, the Board notes
that provided details on their existing legislative frame- that Saudi Arabia has not yet used the PEN Online system
works and the means and extent to which they are able to
cooperate and exchange information and intelligence 5
On the basis of information provided by importing countries on
with counterparts abroad, as well as other relevant form D, INCB is also aware of significant exports of acetic anhydride and
­innovative approaches. ephedrines from Taiwan Province of China.
 II. Action taken by Governments and the International Narcotics Control Board   7

for any export. The Board therefore reminds substances into context. Often, estimates of annual legiti-
Governments of exporting countries of their obligation mate requirements are the very first – and sometimes the
under article 12 of the 1988 Convention to provide noti- only – tangible point of reference to assess the legitimacy of
fication regarding exports of chemicals before such a proposed import. The estimates are presented in annex V
exports depart from their territory. Using the PEN to the present report. Regular updates are available on the
Online system is the most efficient and effective way to INCB website.
provide such notification.
44. As at 1 November 2019, 169 Governments had
41. Another example is the monitoring of trade in ­provided at least one such estimate. This figure includes
­ephedrine, pseudoephedrine and other controlled precur- the Governments of Sierra Leone, South Sudan and
sors in the form of pharmaceutical preparations, as the latter Suriname, which submitted their estimates for the first
are not under international control and the sending of pre- time. It also includes a number of territories and States
export notifications for such preparations, although highly that are not yet parties to the 1988 Convention. However,
recommended,6 is not mandatory. The Board commends there are still 36 States parties to the Convention that
the 30 Governments, namely, those of Australia, Yemen have not yet provided any estimates. Of those, 42 per cent
and the 28 States members of the European Union, that are in Africa; 19 per cent in Oceania; 14 per cent in the
require the sending of pre-export notifications to the Americas; 14 per cent in Europe, and 11 per cent in Asia
authorities of importing countries prior to a proposed (see figure I).
export of preparations, as well as the 24 Governments
that requested to be notified prior to a shipment to their Figure I. Percentage of States parties that have not
territory and/or that apply another system of authoriza- yet provided, pursuant to Commission on
tion to imports of preparations, as such measures help to Narcotic Drugs resolution 49/3, any
maintain a closed loop of monitoring. estimated annual ­legitimate requirements
for precursors of ­amphetamine-type
42. Additionally, INCB commends Governments that stimulants, by region, 2019
voluntarily report on trade in ephedrines in any form, as
such information serves to ensure a comprehensive pic-
ture of global trade and the potential for diversion. INCB
wishes to reiterate its view on the importance of gather- 11%
ing information and hard evidence to prove any
­diversion and actual use of a particular pharmaceutical
14% Africa
product in the illicit manufacture of drugs, so as to 42% Oceania
­provide the authorities of the countries concerned with
Americas
a factual basis for denying shipments of such products. Europe
14% Asia

F. Annual legitimate requirements

19%
for imports of precursors of
amphetamine-type stimulants
43. In the light of widespread illicit manufacture and
abuse of amphetamine-type stimulants since the mid-1990s,
the Commission on Narcotic Drugs, in its resolution 49/3, 45. On form D for 2018, more than 95 Governments
requested Member States to provide to INCB estimates of reconfirmed or updated their estimated annual legitimate
their annual legitimate requirements for precursors of four requirements. However, there are still Governments
amphetamine-type stimulants, namely, 3,4-MDP-2-P, worldwide that have never updated their requirements or
­pseudoephedrine, ephedrine and P-2-P, and, to the extent have not updated them for several years. Forty-six per cent
­possible, estimated requirements for preparations contain- of those are in Africa. INCB recommends that
ing those substances. Since then, the Board has compiled Governments review their annual legitimate require-
those estimates, which are used by INCB and exporting ments for individual precursors at least once a year and
countries to put the size of proposed shipments of these inform the Board of any necessary changes. Such
changes can be communicated to the Board on form D
by the deadline or by official correspondence at any time
6
See, for example, resolution 54/8 of the Commission on Narcotic
Drugs. during the year.
8   INCB REPORT ON PRECURSORS 2019

46. INCB continues to be concerned about the number 49. Information on methodologies to establish estimated
of regions with comparatively high estimated annual legit- annual legitimate requirements is available in the Guide on
imate requirements for, and sometimes also comparatively Estimating Requirements for Substances under International
high imports of, ephedrines, yet the Board has not been Control, developed by INCB and the World Health
able to fully determine the end uses of these substances in Organization, as well as in the document entitled “Issues that
such large quantities in the countries concerned or, if the Governments may consider when determining annual legiti-
shipments are destined for export, in the countries of des- mate requirements for ephedrine and pseudoephedrine”.7
tination. This applies in particular to countries in Africa INCB continues to encourage Governments to develop
(see paras. 87–88) and West Asia. Since the Board’s previ- tailored approaches and methodologies and to inform it
ous report on precursors, significant increases in estimated of those that they have found useful in preparing e­ stimates
requirements for ephedrine and/or pseudoephedrine have of their annual legitimate requirements for precursors.
been reported by Bolivia (Plurinational State of), Bosnia
and Herzegovina, Chile, Greece, the Republic of Korea,
Saudi Arabia, the Sudan and Uganda. Notable decreases in G. Pre-export notifications and
estimated requirements, typically for pseudoephedrine as utilization of the Pre-Export
a raw material, were reported by Afghanistan; Argentina;
France; Hong Kong, China; Israel; the Lao People’s
Notification Online system
Democratic Republic; Romania; and Turkey. INCB is in 50. One of the most effective measures to identify suspi-
the process of clarifying relevant significant revisions of cious transactions and prevent diversions continues to be
estimates with the Governments concerned. the real-time exchange of information between
Governments of exporting and importing countries and
47. Over the last two years, the Board has made the fol- territories about planned individual shipments of precur-
lowing additional observations in relation to requirements sors. In that regard, the international precursor control
for ephedrine and/or pseudoephedrine: system offers countries two complementary tools: invok-
ing article 12, subparagraph 10 (a), of the 1988 Convention,
(a) Several proposed shipments of notable size were which makes it mandatory for the exporting country to
destined for countries that had never estimated their needs send pre-export notifications, and registering with the
for the substances; Board’s PEN Online system to exchange pre-export notifi-
cations online and in real time. Upon receiving pre-export
(b) In some cases, proposed imports exceeded esti- notifications, importing countries can verify the legiti-
mated needs; conversely, some Governments had built in macy of individual transactions and identify suspicious
substantial safety margins by making estimates of require- shipments.
ments that were far higher than actual imports;

(c) Major increases in estimated annual legitimate 1. Pre-export notifications

requirements have sometimes been justified by the need to
51. As at 1 November 2019, 113 States and territories
meet the demand of a new customer within the country, or
had formally requested pre-export notifications pursuant
even abroad (re-export) (see box 1).
to article 12, subparagraph 10 (a), of the 1988 Convention,
a number that has remained unchanged since the Board’s
48. INCB reiterates that, although the submission of esti-
2018 report on precursors (see annex VI). By region, the
mated annual legitimate requirements to the Board is vol-
percentage of countries that had invoked article 12, sub-
untary, knowledge of national needs for precursors, and
paragraph 10 (a), were as follows: Europe, 73 per cent; the
related import requirements, remain key factors in pre-
Americas, 69 per cent; Asia, 68 per cent; Africa, 31 per
venting diversion. Therefore, INCB reiterates its recom-
cent; and Oceania, 25 per cent (see figure II). In some
mendation that importing Governments regularly
regions, in particular Africa and Oceania, Governments
assess their annual legitimate requirements for individ-
have continued to leave it to the discretion of the authori-
ual precursors to ensure that they always reflect the
ties of exporting countries and territories to inform them
most recent market conditions. Furthermore, INCB
of planned shipments of controlled precursors. The Board
encourages the competent authorities of exporting
encourages Governments that have not yet done so to
countries to use the published estimates of importing
invoke their right to be pre-notified of all precursor
countries and suspend exports until initial doubts about
exports destined for their territory.
their legitimacy have been dispelled or actual discrep-
ancies have been resolved.
7
Both documents are available on the INCB website.
 II. Action taken by Governments and the International Narcotics Control Board   9

Figure II. Percentage of countries that invoked 54. Africa and Oceania remain two regions of concern.
article 12, subparagraph 10 (a), of the The low percentage of Governments in those regions that
1988 Convention, by region, 2019 have invoked article 12, subparagraph 10 (a), and that
have thus officially requested to receive pre-export
­notifications, make them prone to traffickers’ diversion
attempts. Countries, in particular, non-traditional trading
Europe 73% countries, where a systematic precursor control mecha-
nism is non-existent or weak, are at a greater risk of being
Americas 69% targeted by traffickers. In this regard, INCB wishes to
point out that only an established control mechanism
Asia 68% will place Governments in a position to comply with
their treaty obligations under the 1988 Convention.
Africa 31% The Board furthermore draws the attention of
Governments to, and urges them to review, the
Oceania 25% ­minimum action for international trade monitoring
through the PEN Online system, summarized in its
2015 report on precursors.9

55. Since the cut-off date for the Board’s 2018 report on
precursors, more than 35,000 pre-export notifications
2. Pre-Export Notification Online
have been submitted through the PEN Online system.
system Although the Board is generally pleased with the number
52. PEN Online, the Board’s automated online system of registered Governments and the number of those that
for exchanging pre-export notifications, launched in view and respond to pre-export notifications received
March 2006, ensures that Governments receive real-time through the system, it is still concerned about the remain-
information about all planned shipments of chemicals ing number of importing Governments (approximately
destined for their territory. The receipt of such pre-export 30 per cent of the total) that very rarely or never view any
notifications enables importing Governments to verify in a notifications, despite having officially requested to be pre-
timely manner the legitimacy of individual shipments in notified (see map 2). Since the previous reporting period,
international trade in precursors, to identify suspicious users of the system in Uzbekistan and Yemen have been
transactions and to prevent diversion into illicit channels. among those that have utilized the system more actively to
view pre-export notifications. By contrast, INCB has noted
53. Registration for the PEN Online system has contin- a decrease in activity by users in, among other countries,
ued steadily. As at 1 November 2019, 164 exporting and India, Indonesia, Nicaragua, Rwanda, Sierra Leone,
importing countries and territories had been authorized to Suriname and Viet Nam. Therefore, INCB reiterates its
access the system. That number includes Angola and recommendation to importing Governments that are
North Macedonia, which have been registered since registered as users of the PEN Online system to make
1 November 2018. The Board encourages the remaining active use of the system for all transactions involving
33 Governments that have not yet registered as users of precursors and to respond to exporting authorities in a
the PEN Online system to do so without delay.8 timely manner where necessary.

8
Those countries are: Antigua and Barbuda, Central African
Republic, Comoros, Democratic People’s Republic of Korea, Djibouti,
Dominica, Equatorial Guinea, Eswatini, Fiji, Gabon, Guinea, Guinea-
Bissau, Guyana, Kiribati, Lesotho, Liberia, Malawi, Mauritania, Monaco,
Mongolia, Mozambique, Nauru, Niger, Palau, Papua New Guinea, Saint
Kitts and Nevis, Samoa, San Marino, Sao Tome and Principe, Tonga,
Turkmenistan, Tuvalu and Vanuatu. 9
E/INCB/2015/4, box 1.
Map 2. Use of the PEN Online system, by percentage of pre-export notifications viewed, 2019
10   INCB REPORT ON PRECURSORS 2019

Hong Kong, SAR of China

Macao, SAR of China

Not registered to PEN Online

No PENs received or less than

10% of incoming PENs viewed
10% to 49% of incoming PENs
viewed

50% to 89% of incoming PENs The boundaries and names shown and the designations used on this map do not imply official endorsement or acceptance by the United Nations.
viewed Final boundary between the Sudan and South Sudan has not yet been determined. Dotted line represents approximately the Line of Control
in Jammu and Kashmir agreed upon by India and Pakistan. The final status of Jammu and Kashmir has not yet been agreed upon by the parties.
More than 90% of incoming PENs A dispute exists between the Governments of Argentina and the United Kingdom of Great Britain and Northern Ireland concerning
viewed sovereignty over the Falkland Islands (Malvinas).
 II. Action taken by Governments and the International Narcotics Control Board   11

56. Less than 6 per cent of proposed exports were that the contact details of the focal points remain up to
objected to during the reporting period, similar to date, INCB encourages all Governments to regularly
previous years. Although many of those objections were review the focal point lists available on the Board’s secure
raised for administrative reasons, it was noted that many website and inform it of any changes in a timely manner.
of the shipments that were objected to had subsequently
been permitted to be released by the importing authori- 60. Multilateral mechanisms established under Project
ties. This might be due to the fact that, in many cases, Prism and Project Cohesion and steered by the INCB
importing Governments convey their objections too rap- Precursors Task Force10 have brought about identifiable
idly, before having concluded their process of verifying the results. Participating Governments have provided and
legitimacy of the respective shipment. The Board there- received information on emerging trafficking trends,
fore recommends that competent authorities utilize the ­identified modi operandi and exchanged data on activities
online conversation tool available in the PEN Online related to the diversion of precursors and non-scheduled
system to communicate to the trading partner any issues chemicals. The Board continued to assist those Governments
regarding a specific shipment and to only use the on a regular basis by serving as a focal point for the exchange
“objection” or “non-objection” function to convey the of such information,11 including through PICS (see sect. 2
importing authority’s final decision, in order to avoid below) and through the dissemination of special alerts, as
confusion among exporting Governments. required. During the reporting period, three special alerts
were circulated to all participating Governments informing
57. Parties are obliged under article 12, paragraph 9, of the them about a fentanyl pre-­precursor and a precursor of
1988 Convention to notify, as soon as possible, the compe- ANPP, about the extension of the ban on issuing import
tent authorities of the Parties concerned if there is reason to authorizations for pseudoephedrine in the Syrian Arab
believe that the import, export or transit of a s­ubstance Republic, and about a suspicious e­ xporting address associ-
listed in Table I or Table II is destined for the illicit manufac- ated with consignments of new psychoactive substances,
ture of narcotic drugs or psychotropic substances. While the fentanyls and precursors.
authorities of importing countries and territories may do so
by objecting to a proposed import or communicating any 61. Following a limited survey in 2018 on specialized
issues regarding a specific shipment through the PEN equipment used in the illicit manufacture of drugs, which
Online communication tool, the Board also encourages provided an overview of the types of equipment most widely
exporting countries to systematically use the PEN Online encountered, in 2019, a tailored intelligence-gathering activ-
system to provide notification of shipments even in cases ity on the types and sources of tableting and encapsulating
where they have concerns about their legitimacy, and if machines used for illicit drug manufacture was conducted
they do so, to clearly indicate that the shipments will not jointly with Project Ion (which focuses on new psychoactive
proceed unless the ­authorities of the importing country substances) and the Board’s Operational Partnerships to
or territory indicate their explicit approval. Interdict Opioids’ Illicit Distribution and Sales (OPIOIDS)
Project. The activity was conducted in connection with the
greater focus the Board has started to place on article 13 of
H. Other activities and the 1988 Convention, to complement its work under
achievements in international ­article 12, with the aim of disrupting illicit drug manufacture
(see also chapter IV). INCB wishes to thank the
precursor control Governments that cooperated with it on m ­ atters relating
to article 13 and encourages Governments to continue to
1. Project Prism and Project Cohesion
participate actively in activities under Project Prism and
58. Project Prism and Project Cohesion are the two Project Cohesion and to provide feedback and timely
international initiatives led by INCB that bring together responses to related enquiries by the Board and other
operational focal points worldwide to address the diver- ­project focal points.
sion of chemicals used in the illicit manufacture of syn-
thetic drugs (Project Prism), and heroin and cocaine 10
The current members of the INCB Precursors Task Force are
(Project Cohesion). Australia, China, Colombia, France, Germany, India, Mexico, the
Netherlands, Nigeria, the Russian Federation, South Africa, Switzerland,
Turkey, and the United States, supported by INCB, the International
59. In 2019, more than 75 Governments reviewed and Criminal Police Organization (INTERPOL), the World Customs
updated their nominations of focal points for the two initia- Organization, the European Commission and the Inter-American Drug
Control Commission.
tives, bringing the number of countries and territories that 11
A summary of the minimum action needed for international
have nominated at least one operational focal point to 144 ­ ultilateral cooperation under Project Prism and Project Cohesion is avail-
m
for Project Prism and 112 for Project Cohesion. To ensure able in the INCB 2015 report on precursors (E/INCB/2015/4), box 2 (p. 9).
12   INCB REPORT ON PRECURSORS 2019

62. In 2019, in the framework of Project Cohesion, intelligence with foreign counterparts, including, in
several operational meetings and informal consulta-
­ ­particular, by users from countries whose contributions
tions were held on the subject of trafficking in acetic are critical to understanding current patterns of trafficking
anhydride and other precursors of heroin. The events in acetic anhydride, such as Afghanistan and Iran (Islamic
brought together case officers from countries in Europe Republic of) (see also chap. III, sect. C).
and West Asia that have been affected by recent cases of
diversion and trafficking. For example, consultations 66. During the reporting period, PICS once again
with the competent national authorities of the United provided an important tool to support cross-border
­
Arab Emirates focused on issues relating to operational ­investigations and identify trafficking routes, ways of mis-
case cooperation and information exchange and/or declaration, modi operandi and new non-scheduled
issues of specific interest, such as the review of proce- ­precursor chemicals. INCB continued to act as a modera-
dures involved in the physical inspection of shipments tor and facilitator, establishing direct contact between
and investigations into suspected diversions of and traf- competent authorities to exchange information on spe-
ficking in precursors in or through free-trade zones. cific incidents and, where sufficient information was
Furthermore, experts from regulatory, law enforcement available, pointing them to possible links between
and judiciary authorities in the Islamic Republic of Iran incidents. The leads that PICS provided to national
­
reviewed recent cases of diversion and trafficking in authorities enabled them to initiate backtracking investi-
precursors of heroin, including acetyl chloride, and gations and, on ­ several occasions, to conduct further
analysed practical solutions for ­ investigations of ­seizures or prevent diversion attempts.
suspected diversion attempts involving legitimate
­
online trading platforms.
3. Voluntary cooperation with industry
63. The INCB Precursors Task Force met twice in 2019,
in March and in October, to discuss progress and plan 67. Public-private partnerships and voluntary
future activities. cooperation with industry remain key elements of an
­
effective strategy to confront chemical diversion. However,
the information INCB had about the level of voluntary
2. Precursors Incident Communication partnerships worldwide continued to be incomplete. A
System survey on national responses to non-scheduled chemicals
provided some insight into the voluntary cooperation
­
64. PICS continued to facilitate global operational arrangements in place among relevant authorities and sec-
­cooperation in precursor-related matters by offering regis- tors of industry, as well as such arrangements in general,
tered users a platform for the real-time exchange of and the Board wishes to thank all Governments who
­information on seizures and other incidents, such as ship- ­participated in that survey.
ments stopped in transit, suspicious shipments and seizures
of clandestine laboratories, involving substances listed in 68. To advance knowledge of the concept of public-private
Tables I and II of the 1988 Convention and substances not partnerships, INCB, in cooperation with the Government of
under international control, as well as drug manufacturing the United Republic of Tanzania, held a workshop on the
equipment (see also chapter IV). topic for countries in East Africa in October 2019. The work-
shop, which brought together Government officials and
65. As at 1 November 2019, PICS had more than 500 reg- industry representatives from nine countries, was facilitated
istered users from 117 countries and territories, represent- by experts from France and Nigeria and resulted in a set of
ing more than 270 agencies.12 More than 2,700 incidents recommendations that participating countries c­ommitted
had been communicated through PICS since its establish- themselves to implementing.
ment in 2012, an average of 350 incidents per year. The
level of usage of the system demonstrates the interest of
69. During the reporting period, INCB continued to
PICS users and case officers in identifying and sharing
focus on raising awareness about the need to extend the
actionable information and intelligence in a timely
scope of cooperation with industry, both within the
manner. The Board notes with appreciation the active
manufacturing industries, by including, for example,
­
utilization of PICS and the continued exchange of
­
companies specialized in customized synthesis, and
­
beyond the manufacturing industries, by including online
12
Governments that have not yet registered PICS focal points for
vendors and platforms. Successes with the latter are
their national authorities involved in precursor control may request an
account by writing to incb.pics@un.org. described in ­chapter III, sect. C, box 3.
 III. Extent of licit trade and latest trends in trafficking in precursors   13

70. INCB wishes to reiterate the importance of substances and on shipments of substances that have
­engaging relevant sectors of industry to ensure the been stopped on the basis of sufficient evidence that
successful and sustainable prevention of chemical
­ the substances may have been diverted into illicit
diversion. INCB also wishes to reiterate that, although channels, is essential to addressing emerging traf-
­determining the nature and extent of such cooperation ficking trends at an early stage and globally. INCB
is the prerogative of individual countries, it is impor- also wishes to remind Governments that thwarted
tant that competent national authorities share attempts to divert a given substance should receive
information about suspicious requests, orders and
­ the same investigative attention that would be
transactions with INCB in order to prevent “company afforded to a seizure of the same substance, since
shopping”, i.e., the ­ shifting from one supplier to such cases provide valuable intelligence that, if
another, across borders. shared internationally, could prevent attempts to
divert the substances from other sources.

4. Tracking of precursor chemicals to

prevent their diversion
A. Substances used in the illicit
71. In response to Commission on Narcotic Drugs manufacture of amphetamine-
resolution 62/1, entitled “Strengthening international
­
type stimulants
cooperation and comprehensive regulatory and institu-
tional frameworks for the control of precursors used in the 1. Substances used in the illicit
illicit manufacture of narcotic drugs and psychotropic
substances”, INCB, in cooperation with the Government of
manufacture of amphetamines
Turkey, convened an expert working group to explore the
possibility, practicability and effectiveness of innovative
(a) Ephedrine and pseudoephedrine
methods to track precursor chemicals, in particular acetic 74. Ephedrine and pseudoephedrine are used in the
anhydride, to prevent their diversion. illicit manufacture of methamphetamine. They are also
both used legitimately for medical purposes and are
72. The working group, which was to be attended by therefore among the most frequently and widely traded
experts and representatives of private entities, was to pre- ­substances included in Table I of the 1988 Convention, in
pare a report for submission to the Commission on the form of both raw material and pharmaceutical prepa-
Narcotic Drugs in March 2020. In addition to focusing on rations. P-2-P, phenylacetic acid, APAAN and a number
tracking in general, the expert working group was to of non-scheduled substances (see also subsects. (c) and
­analyse the pros and cons of tagging. (d) below, and annex VIII) may be used as substitutes for
ephedrine and pseudoephedrine in the illicit manufacture
of methamphetamine.

III. Extent of licit trade Licit trade

75. Between 1 November 2018 and 1 November 2019,
and latest trends Governments sent more than 5,100 pre-export notifica-
tions for planned shipments of ephedrine and
in trafficking in ­pseudoephedrine through the PEN Online system. The
shipments consisted of approximately 1,500 tons of
precursors pseudoephedrine and 120 tons of ephedrine. The ship-
ments originated in 39 exporting countries and territo-
ries and were destined for 178 importing countries and
73. The present chapter is based primarily on data territories. The table below presents the 10 largest
provided by Governments on form D. Other sources of importers and exporters of ephedrines, ranked in terms
information include the PEN Online system, Project of volume notified through the PEN Online system, in
Prism, Project Cohesion, PICS, and national reports the period 2016–2018.
and other official information from Governments. The
analysis covers the period up to 1 November 2019.
INCB would like to remind Governments that com-
prehensive and timely information on seizures of
14   INCB REPORT ON PRECURSORS 2019

Table. The 10 largest importers and exporters of from Jordan declined significantly in the first 10 months
ephedrines, by volume, 2016–2018 of 2019 (see figure III), the Board is concerned that
­companies in other countries may now be targeted by
Ranking Importers Exporters
traffickers as potential sources of those substances. For
example, at the time of writing, INCB was in the process
1 United States India
of following up on a single proposed shipment of more
2 Switzerland Germany
than 36 million tablets containing pseudoephedrine
3 Republic of Korea Switzerland
(2 tons) from the United Arab Emirates to the Kurdistan
4 Egypt China
region of Iraq. As in the past, the competent authority of
5 France Singapore Iraq objected to all proposed exports destined for the
6 Turkey France Kurdistan region of the country that were notified
7 Pakistan United States through the PEN Online system.
8 Singapore United Kingdom
9 Indonesia Jordan
10 Jordan Belgium Figure III. Preparations containing ­pseudoephedrine
notified through the PEN Online system
for export to Iraq, 2015–2019
35,000

76. Re-exports constitute a significant proportion of

30,000
legitimate trade in ephedrines and there are a number of
countries that are major traders in the substances. This
25,000
makes licit trade monitoring more complex and requires
Amount (kilograms)

that the authorities of both exporting and importing coun-

20,000
try take full responsibility for making sure that each
­transaction is legitimate and meets the uses and needs of 15,000
the importing country.
10,000
77. An important tool to help put licit trade into
context are the estimated annual legitimate require-
­ 5,000
ments for ephedrines, which INCB compiles and makes
available on its website, pursuant to Commission on 0
Narcotic Drugs resolution 49/3 (see also chap. II, sect. F 2015a 2016 2017 2018 2019b
and annex V). Major increases in annual legitimate
requirements and/or in actual imports are important
Exported by Jordan Exported by other countries
signals for intervention by the authorities of exporting
countries and the Board.
a
No data available for Jordan.
b
Data only cover the first 10 months of 2019.
78. Over the past several years, following bans on the
issuance of import authorizations for pseudoephedrine in
the Syrian Arab Republic,13 imports of the substance by 80. Other countries for which INCB has noted increases
several countries in Central and West Asia have increased in proposed shipments of pseudoephedrine notified
significantly. These include Iraq (Kurdistan region), through the PEN Online system include the Sudan and
Kyrgyzstan and the United Arab Emirates. Yemen (see figure IV). INCB encourages the authorities of
exporting countries to be vigilant about pseudoephed-
79. In the past, the Board has alerted the Government rine shipments to those countries, within the limits of
of Jordan to the unprecedented pattern of imports of their responsibility, and to ensure that the pseudoephed-
pseudoephedrine and subsequent exports of prepara- rine supply remains adequate while preventing its
tions containing that substance to the Kurdistan region diversion into illicit channels. In 2019, the estimated
­
of Iraq. Although proposed exports of those preparations annual legitimate requirements for imports of
­pseudoephedrine (both raw material and in the form of
13
In 2019, the Government of the Syrian Arab Republic again pharmaceutical preparations combined) amounted to
extended the moratorium on the approval of pseudoephedrine imports,
5.5 tons for the Sudan and 6 tons for Yemen.
until the end of 2019. As in the past, INCB has disseminated information
about the moratorium to competent national authorities worldwide.
 III. Extent of licit trade and latest trends in trafficking in precursors   15

Box 1. Risk factors for diversion

INCB has previously expressed concern about the risk that traffickers might exploit the lack of effective government
control of certain territories in order to divert precursors. However, conflict and limited government control are not the
only risk factors for diversion. At the national level, competing incentives and interests between different national
authorities, excessive levels of bureaucracy and inadequate capacity to enforce existing legislation also present signifi-
cant risks to effective precursor control. In addition, a major loophole in monitoring international trade in ephedrines
remains the lack of systematic control of pharmaceutical preparations containing those substances. The Board has
observed that competent national authorities, in the absence of clear national regulations, sometimes face difficulties
objecting to exports even when those exports are suspicious. The Board has also observed several instances of imports
of raw materials for the manufacture of pharmaceutical preparations that were subsequently exported without the neces-
sary scrutiny, often to countries with limited regulatory oversight. In some cases, the countries importing the raw material
for processing into preparations increased their estimated requirements for the sole purpose of meeting the demand
of an alleged new export market. INCB once again urges all Governments to make every effort to address loopholes
of this kind in international precursor control efforts.

Figure IV. Imports of pseudoephedrine into the ­ seudoephedrine were reported to INCB by 35 countries
p
Sudan and Yemen notified by exporting and territories in all regions. Nevertheless, reported
countries through the PEN Online system, ­seizures of precursors continued to fall short of explaining
2014–2019 the amount of end products seized.

6,000
Africa
5,000
83. On form D for 2018, four Governments in Africa
Amount (kilograms)

4,000 reported seizures of ephedrine or pseudoephedrine, of

3,000
which two were in West Africa. Specifically, these were
Nigeria, which reported 16 seizures of ephedrine, totalling
2,000 almost 330 kg, and Benin, where a negligible amount of
pseudoephedrine preparations was seized. However, from
1,000
other sources, the Board is aware of seizures of ephedrine
0 in Ghana in 2018, as well as the suspected diversion of
2014 2015 2016 2017 2018 2019a ephedrine from Ghanaian companies and its smuggling
into Nigeria, a development that is believed to have started
Imports into the Sudan Imports into Yemen in 2017.
ALRb Yemen ALRb Sudan
84. Illicit methamphetamine manufacture has been
a
Data only cover the first 10 months of 2019. encountered in the West African subregion since 2011,
b
ALR = Estimated annual legitimate requirements.
when the first operational laboratories were dismantled in
Nigeria. Since then, a total of 16 illicit methamphetamine
laboratories have been uncovered in different parts of
Trafficking Nigeria (see figure V). With the exception of one laboratory
81. The use of ephedrines in the illicit manufacture of dismantled in 2016 in which P-2-P was manufactured from
methamphetamine is predominant in Asia and Oceania, non-­ scheduled, off-the-shelf chemicals by means of the
Africa and some regions in Europe. In North America, the ­so-called nitrostyrene method,14 illicit manufacture in all
bulk of illicitly manufactured methamphetamine is made other laboratories has employed ephedrine-based methods.
using P-2-P-based methods.

82. Seizure reports for 2018 continued to substantiate

the global spread of illicit methamphetamine ­manufacture.
14
E/INCB/2016/4, para. 67.
In 2018, seizures of almost 40 tons of ephedrine and
16   INCB REPORT ON PRECURSORS 2019

Figure V. Methamphetamine laboratories Figure VI. Proposed imports of ephedrines into

­dismantled in Nigeria, 2011–2019 Nigeria and corresponding estimated
annual ­legitimate requirements,
2015–2019
4
Number of laboratories dismantled

25,000
3
20,000

Amount (kilograms)
2
15,000

1
10,000

0 5,000
2011 2012 2013 2014 2015 2016 2017 2018 2019a
0
2015 2016 2017 2018 2019a
a
Data only cover the first 10 months of 2019. Ephedrine (all forms)
Pseudoephedrine (all forms)
ALRb (ephedrine including prepara�ons)
ALRb (pseudoephedrine including prepara�ons)
85. The modi operandi for obtaining ephedrine for illicit
purposes mostly involved diversion after importation, i.e.,
within the countries concerned in West Africa. As the Board a
Data only cover the first 10 months of 2019.
has previously noted, under increased scrutiny related to b
Estimated annual legitimate requirements.
imports of ephedrine into Nigeria, traffickers appear to have
exploited neighbouring countries to divert the substance
from domestic distribution channels after it was cleared for 88. The Board also notes that Nigeria, with an annual
importation, subsequently smuggling it into Nigeria.15 legitimate requirement for ephedrines of almost 31 tons,
ranked among the 20 countries with the highest annual
86. In 2019, the follow-up on a controlled delivery and legitimate requirements for those substances (the com-
seizure of 100 kg of ephedrine smuggled from Ghana, via bined annual legitimate requirements for raw materials
Togo and Benin, led to the latest discovery of an illicit and preparations). Ghana, with an annual legitimate
methamphetamine laboratory in Nigeria, in March 2019. requirement of 8 tons, ranked 32nd, and both countries’
The chemicals and equipment recovered from the illicit lab annual legitimate requirements were well above the global
had been procured on the licit market. median of 1.1 tons (see annex V for annual legitimate
requirements globally). Countries in Africa with estimated
87. An analysis of data from the PEN Online system for annual legitimate requirements equal to or greater than
the past five years shows that the volume of proposed the median also included, in descending order, Egypt,
imports of both ephedrine and pseudoephedrine into Algeria, South Africa, Uganda, Kenya, the Sudan, the
Nigeria was already higher in the first ten months of 2019 United Republic of Tanzania, Tunisia, Morocco, South
than in the previous entire years (see figure VI). INCB is Sudan, the Democratic Republic of the Congo and
aware that the Government of Nigeria, with assistance Ethiopia. Mali is the only country in Africa that has pro-
from UNODC, is in the process of assessing the country’s hibited the import of ephedrines, a measure implemented
needs for certain medications, including ephedrines. by Mexico, and by many countries in Central America,
However, to date, the annual legitimate requirements for after that region was targeted by traffickers for large-scale
ephedrine and pseudoephedrine have not been revised. diversions of ephedrines (see also para. 97)

15
E/INCB/2018/4, para. 94.
 III. Extent of licit trade and latest trends in trafficking in precursors   17

Figure VII. Proposed imports of ephedrines into 93. South Africa remained a destination for small-scale
Ghana and corresponding estimated ephedrine shipments (up to 15 kg in an individual
annual ­legitimate requirements, ­consignment). Smuggling was reported to have occurred
2015–2019 by air, using couriers or postal services, from a number of
countries, including Ethiopia, Germany, India, Nigeria
6,000 and the United Republic of Tanzania; the United Arab
Emirates is mentioned as transit country for smuggling
5,000 from India.
Amount (kilograms)

4,000
94. Incidents of smuggling of ephedrines involving
3,000
countries in Africa and amounts of up to 200 kg also con-
2,000 tinued in 2019.

1,000
South America and Central America and
0
2015 2016 2017 2018 2019a the Caribbean
Ephedrine (all forms)
Pseudoephedrine (all forms)
95. In 2018, two countries in South America reported
ALRb (ephedrine including prepara�ons) seizures of ephedrine or pseudoephedrine. No seizures of
ALRb (pseudoephedrine including prepara�ons) ephedrines were reported in 2018 by any country in
Central America and the Caribbean.
a
Data only cover the first 10 months of 2019.
b
Estimated annual legitimate requirements. 96. Argentina reported a seizure of 160 kg of ephedrine.
The amount was seized in a single incident and is related
to diversions in 2006 and 2007. INCB is aware of a similar
89. Against this background, and considering that the incident in Argentina in 2016, when 250 kg of ephedrine
most recent diversions in countries of West Africa were seized.16 That amount was imported in 2011 but
occurred after imports had been cleared by the importing never collected by the importer. Both incidents appear to
countries’ authorities, i.e., within the importing country, be linked with large-scale precursor diversions in
the Board recommends increased scrutiny of the Argentina that were already the subject of investigations
­specific end uses of and actual needs for ephedrines, some 10–12 years ago.17 Argentina had subsequently
whether as raw material or in the form of pharmaceuti- ­scrutinized the verification of importing companies and
cal preparations, for final consumption, export or the legitimacy of the end use of the substance, and as a
re-export. result, subsequently reorganized its control system.

90. Moreover, in 2018, an incident of domestic diversion 97. Also approximately 10–12 years ago, in addition to
was reported in the United Republic of Tanzania. It Argentina, several other countries in Central and South
involved 8 kg of pseudoephedrine that was diverted from America were targeted by organized criminal groups for the
the manufacture of cough syrup. A total of 10,000 litres of purposes of acquiring ephedrines and subsequently smug-
syrup containing less of the active ingredient were also gling them from the domestic markets of those countries
seized. Investigations are ongoing. into North America. The smuggling was revealed during the
INCB-led Operation Ice Block and involved Guatemala,
91. Nigeria continued to be a source for ephedrine Honduras and Nicaragua. In response to the diversions, and
smuggled abroad, mostly to Mozambique and South following the ban by Mexico on imports of ephedrines in
Africa, although Cameroon and the United Republic of 2009, several countries in Central America strengthened
Tanzania were also destination countries. their laws related to ephedrine and ­ pseudoephedrine.
According to open source information, in August 2019,
92. Mozambique reported seizures of 62 kg of e­ phedrine, related to those past diversion incidents, a New York federal
smuggled from India. The Board is also aware of ephedrine court sentenced a former Honduran drug trafficker to life in
smuggling using falsified labels from a manufacturer in prison for distributing, among other substances, 20 tons of
India. Such incidents were encountered in Egypt, the Syrian ephedrine.
Arab Republic and Turkey. Although the falsification of the
labels was proved, the source or sources of the smuggled 16
E/INCB/2017/4, para. 100.
ephedrine were still unknown at the time of writing. 17
E/INCB/2008/4, para. 49.
18   INCB REPORT ON PRECURSORS 2019

North America ­ anufactured (see para. 149). The authorities of China

m
also noted a shift in illicit drug manufacturing activities to
98. In 2018, the situation in North America remained other places with weaker controls both within China and
unchanged compared with previous years, with only small abroad. Within China, 268 clandestine laboratories were
amounts of ephedrines and their preparations having been dismantled in 2018, approximately 15 per cent fewer than
seized. The United States reported seizures totalling 1.5 kg in 2017. This was due in particular to a major decline in
of ephedrine and 28 kg of pseudoephedrine, partly in the Guangdong province, one of the provinces most heavily
form of single dosage units. These key precursors, as well affected by illicit manufacture in the past.
as essential chemicals such as hydriodic acid, iodine, red
phosphorous and lithium metal, are often diverted from 103. The second largest seizures of ephedrines reported by
legitimate markets to feed the more than 1,500 user-based a country in East and South-East Asia in 2018 were reported
clandestine methamphetamine laboratories in the country. by the Philippines. They totalled more than 11 tons of
A continuing trend has been the smuggling of metham- ephedrine, the largest amount ever reported by that country.
phetamine in liquid form into the United States, which is No further details were provided; the origin was unknown.
subsequently recovered (crystallized) using a common
solvent, such as acetone. 104. Seizures of ephedrine in Malaysia amounted to
nearly 200 kg. The substance was seized in illicit metham-
99. In May 2019, Canada seized a record amount of 700 kg phetamine laboratories and was suspected to have been
of ephedrine tablets in a multi-drug seizure. Investigations diverted domestically. Myanmar reported seizures of
are ongoing. almost 140 kg of ephedrine preparations, suspected to
have originated in China, and 7.6 kg of pseudoephedrine
East and South-East Asia preparations, from India. The amounts fell short of the
suspected manufacturing capacity of methamphetamine
100. The illicit manufacture of methamphetamine in East laboratories dismantled in Myanmar in 2018.
and South-East Asia has traditionally been ephedrines-
based, but with subregional specificities. Although a method 105. Hong Kong, China, reported the seizure of approxi-
known as the Emde method, which uses thionyl chloride, mately 11 kg of ephedrine in two outbound ephedrine
and chloroephedrines as chemical intermediates, has been consignments pending export to the United Kingdom of
predominant in South-East Asia, traffickers in East Asia Great Britain and Northern Ireland. Both cases occurred
more typically rely on a method known as the Nagai in 2017 but were only confirmed in 2018 and involved the
method, which requires red phosphorous and iodine or any trans-shipment of misdeclared express mail packages, a
of their substitutes (see also paras. 150–151). More recently, modus operandi also encountered in New Zealand.
experts and some limited forensic studies have identified
the use of P-2-P-based methods in the illicit manufacture of 106. The Board now understands from forensic ­impurity
methamphetamine. Nevertheless, and despite a significantly profiling studies in China of seized methamphetamine
increased focus on enhancing precursor control in recent smuggled from the Golden Triangle in the second half of
years, in particular in South-East Asia, details about the 2018 that the proportion of methamphetamine that was
­precursors identified in the region remain scarce or have manufactured using P-2-P-based methods increased to
not been reported to INCB, limiting the ability of the Board approximately 20 to 30 per cent (from an estimated 10 per
and of countries that are claimed to be the origin of cent previously). Profiling data further suggest that benzyl
­chemicals to address any existing weaknesses. cyanide (also known as phenylacetonitrile), a chemical
not included in Table I or Table II of the 1988 Convention
101. In 2018, six countries and territories in East and but included in the limited international special surveil-
South-East Asia reported seizures of ephedrines. Following lance list, might be used as starting material to synthesize
two consecutive years of reporting seizures of between 1 P-2-P (see also para. 146). According to the profiling
and 4 tons of preparations containing pseudoephedrine, results, the remaining 70 to 80 per cent of methampheta-
Thailand did not provide any seizure data for substances mine is manufactured from ephedrine using the Emde
listed in Tables I and II of the 1988 Convention in 2018. method. Most of the ephedrine is synthesized illicitly
from 2-bromopropiophenone or its precursors and
102. China seized almost 20 tons of ephedrine raw ­pre-precursors (see para. 149).
­material and 6 tons of preparations, in addition to 908 kg
of pseudoephedrine. Unfortunately, no further ­information 107. Given the continued scarcity of information from,
was provided. However, the Board assumes that, as in and the Board’s difficulties communicating with several
previous years, the bulk of the ephedrine was illicitly
­ countries in, East and South-East Asia, INCB once again
 III. Extent of licit trade and latest trends in trafficking in precursors   19

urges the Governments in the region to cooperate with 110. Afghan authorities did not report any ephedra
each other and with the Board with a view to identifying ­seizures on form D for 2018. Seizures of ­pseudoephedrine
the types of precursors, their points of diversion and the were comparatively small (50 kg), with an alleged origin in
modi operandi used by traffickers, as well as to addressing the Islamic Republic of Iran.
their diversion, investigating precursor-related i­ncidents
and allowing criminal activities to be prosecuted. INCB
South Asia
also once again calls on the United Nations Office on
Drugs and Crime to support countries in the region in 111. Seizures of ephedrines in India in 2018 totalled more
fulfilling their obligations under the 1988 Convention and than 330 kg. Through PICS, INCB is aware of the amounts
in preventing and investigating precursor-related cases, seized in individual seizures, which ranged from 20 grams
including by enhancing the capacity for the field detection to more than 120 kg, and from 1,000 to 1.12 million tablets,
and identification of emerging precursors. but which were typically small (less than 15 kg). The seized
substance typically originated in India and was destined for
countries in Africa (Ethiopia, Malawi, Nigeria, South
West Asia
Africa, United Republic of Tanzania, Zambia and
108. In 2018, two countries in West Asia, Afghanistan and Zimbabwe), East and South-East Asia (Malaysia) and West
Georgia, reported seizures of ephedrines. Overall, the Asia (Oman and Saudi Arabia). One seizure of 123 kg orig-
amounts seized, and the information provided to INCB inated in Myanmar. Seizures communicated through PICS
remained insufficient for a meaningful assessment of the sit- in 2019 followed the same pattern with regard to the
uation with regard to methamphetamine precursors in West amounts seized and the destination countries, with the
Asia. At the same time, the estimated annual legitimate exception of Australia and the Congo, which were new des-
requirements for ephedrines in several countries in the tination countries in 2019. Follow-up investigations into
­subregion remained comparatively high. Pakistan, the Syrian interception of 25 kg of pseudoephedrine at an airport
Arab Republic, Jordan, Saudi Arabia, Turkey and Iraq, in resulted in the seizure of more than 1.8 tons of the s­ ubstance
that order, ranked among the 20 countries with the highest and of an illicit laboratory.
annual legitimate requirements for ephedrines (combined
annual legitimate requirements for raw materials and prepa-
Europe
rations containing ephedrines); Pakistan ranked among the
10 countries with the highest such requirements. 112. In 2018, 18 countries in Europe reported seizures of
ephedrines, totalling approximately 180 kg of ephedrine
109. A development of concern is the rise in illicit meth- and 270 kg of pseudoephedrine. This represented a
amphetamine manufacture in Afghanistan, to which the ­significant increase from 2017, although from low levels.
Board has drawn attention since 2015.18 Initially, ephed- Between 60 and 70 per cent of the amounts seized was in
rines from pharmaceutical preparations, including in the the form of preparations. The increase may be due to two
form of syrup, were believed to have fuelled illicit manu- developments: (a) the use of European countries as trans-
facture. In 2018, INCB became aware of seizures of the shipment points to disguise the origin of ephedrines from
Ephedra plant, which grows wild in the mountains of Asia destined for Africa and Oceania; and (b) an increase
Afghanistan. Although it is a new development of concern in illicit methamphetamine manufacture in Europe.
in Afghanistan, the use of wild grown ephedra in illicit Although such manufacture in the past was largely c­ onfined
methamphetamine manufacture is not a new phenome- to small-scale, user-based laboratories in Czechia and
non and has been observed in the past, for example, in countries bordering Czechia, there are now concerns
countries in Central Asia. Given the conducive growing among authorities about the growing indications of organ-
conditions in the mountainous areas of Afghanistan, it is ized criminal groups’ interest in illicit methamphetamine
becoming increasingly important to understand the extent manufacture in Europe more widely.
of the availability of ephedra in the country, how it reaches
illicit methamphetamine laboratories, and which other 113. In recent years, the authorities of Czechia have
key chemicals and equipment are used, and their sources, observed an increase in large, industrial-scale laboratories,
so as to quickly develop strategies to disrupt at an early typically run by organized criminal groups, to meet
stage the supply from what appears to be a new, growing demand abroad. In addition, in 2018, there was at least one
illicit drug industry in Afghanistan. laboratory that focused purely on extracting pseudoephed-
rine from tablets. The authorities of Czechia also noted a
shift of larger-scale laboratories to other countries, namely
to Poland, Germany or the Netherlands, as well as a trend
18
E/INCB/2015/4, para. 73. towards each facility being used for one or two cycles only.
20   INCB REPORT ON PRECURSORS 2019

Access to chemicals, the avoidance of detection and 119. On form D for 2018, Ukraine reported a number of
­differing levels of punishment are suspected driving f­ actors small seizures of pseudoephedrine preparations, totalling
for this development. just 3.5 kg, with the substance originating in a range of
countries, including Israel (10 seizures), Turkey (5 seizures),
114. Polish authorities have confirmed this ­development, Egypt, the Syrian Arab Republic and a number of countries
having observed a significant increase in dismantled in Europe. In addition, the authorities of Ukraine noted a
methamphetamine manufacturing sites in recent years. steady flow of preparations containing pseudoephedrine in
Whereas before 2015, a maximum of three methampheta- individual amounts of 5,000 to 35,000 60-mg tablets from or
mine laboratories had been dismantled in Poland ­annually, through European countries during 2018.
five such laboratories were dismantled in 2016, nine in
2017 and seven in 2018. 120. Through PICS, INCB is also aware of a number of
incidents that occurred between October and December 2018
115. In 2019, authorities in Belgium dismantled a fully and in May 2019 involving the smuggling of pseudoephed-
equipped methamphetamine laboratory that contained rine from Egypt to Ukraine via Germany. The incidents
notable amounts of chemicals, and authorities in the involved pseudoephedrine raw material in individual
Netherlands dismantled a “floating” methamphetamine lab- amounts ranging from 3 kg to almost 10 kg. It is the Board’s
oratory on board a large cargo ship, from which more than understanding that investigations are ongoing. Similarly, in
300 litres of methamphetamine oil and drug-­manufacturing 2018 and 2019, Germany intercepted a number of ephedrine
equipment were also seized. shipments in transit from India to countries in Africa
(Malawi, South Africa and Zambia), and from Liberia and
116. In terms of precursors, in 2018, nearly 60 kg of Nigeria to Australia and New Zealand.
­pseudoephedrine preparations, twice the amount reported
in 2017, were seized in Czechia. Individual seizures
involved small amounts, i.e., there were nearly 100 ­seizures, Oceania
of which 76 (in the amount of 55 kg) involved Poland as a 121. In 2018, the situation regarding ephedrines in
country of origin. Countries in South-Eastern Europe were Oceania remained unchanged, with limited information
also mentioned. about seizures and diversions of those substances, and
their sources. Over the last several years, ephedrine has
117. Authorities in Hungary seized almost 125 kg of almost entirely replaced pseudoephedrine as the main
preparations containing ephedrine, in individual methamphetamine precursor seized in Australia and New
amounts ranging from less than 100 grams to more than Zealand. This trend is likely linked with the emergence of
60 kg. According to the authorities of Hungary, the illicitly manufactured ephedrine in China, which has
modus ­operandi of the trafficking often involved citizens made the diversion of pseudoephedrine and preparations
of Czechia who were paid to purchase and/or smuggle containing pseudoephedrine less lucrative.
the tablets. The majority of incidents occurred at the
border between Serbia and Hungary. Some of the prepa- 122. According to the Australian Criminal Intelligence
rations were purchased in Bulgaria and the consign- Commission, the number of detections of methampheta-
ments were often destined for Czechia. Some incidents mine precursors at the Australian border decreased by
involved tablets without imprints that may have been nearly 40 per cent, while the weight of intercepted ship-
illicitly compressed solely for the purposes of smuggling ments increased by more than 200 per cent, indicating
and evading controls. The authorities of Hungary also fewer but larger interceptions.19 This trend continued in
reported the dismantling of one illicit methampheta- 2019, when Australian authorities seized 1.3 tons of ephed-
mine laboratory. rine from a container in Melbourne harbour, following a
tip-off from the National Narcotics Control Commission
118. Seizures of ephedrine in Ireland (10 kg) and the of China. The container was labelled as containing ceramic
United Kingdom (12 kg) appear to have been trans-ship- tiles and glue. It is likely that the ephedrine was of illicit
ments destined for Australia or New Zealand. To help origin, an important aspect of the case that the Board is
determine whether there are any weaknesses in the still verifying with the authorities concerned.
­control system for ephedrine, or whether the seized
ephedrine was illicitly manufactured (requiring a differ-
ent approach), the Board encourages the countries
where seizures of ephedrine are made to subject the 19
Australian Criminal Intelligence Commission, Illicit Drug Data
seized substance to forensic profiling analysis. Report 2017–2018 (Canberra, July 2019).
 III. Extent of licit trade and latest trends in trafficking in precursors   21

123. In the period 2017–2018, the majority of and territories and amounted to more than 27 tons of raw
­methamphetamine precursors detected were encountered material and more than 10 tons of pharmaceutical prepara-
in the international mail stream (53 per cent); by weight, tions. Compared with the previous reporting period,
sea cargo accounted for the greatest proportion of border imports of norephedrine (in all forms) into countries in
detections (85 per cent). In terms of total weight of seized East and South-East Asia increased by nearly 50 per cent.
precursors, Thailand was the main embarkation point. As in the past, small-scale trade in ephedra was only
Increases in precursor seizures indicate that the domestic reported by Germany.
manufacture of methamphetamine, as well as the importa-
tion of methamphetamine as a final product, may be on Trafficking
the rise. Specifically, authorities believe that large-scale
128. On form D for 2018, the United States was the
clandestine laboratories may exist throughout Australia.
only country to report a seizure of norephedrine, albeit
in an insignificant amount (7 kg). No seizure of ephedra
124. On form D for 2018, New Zealand reported s­ eizures
was formally communicated to INCB. However, in the
of 412 kg of ephedrine. This was a significant decrease from
light of the anecdotal information from Afghanistan (see
2017, when 723 kg was seized, and represented a continued
para. 109), the Board wishes to remind Governments to
downward trend since 2016. It is unclear what has prompted
remain alert with regard to ephedra and other natural
this decline; however, the authorities of New Zealand
sources of ephedrine, and to consider adopting
­suspect that it might be more cost-effective for traffickers to
­adequate measures to reduce the risk of their use in
import methamphetamine as a finished product, rather
illicit drug manufacture.
than precursors, for use in domestic illicit manufacture.
From 1 January 2019 until mid-2019, police and customs
officials had seized more than 150 kg of ephedrines. (c) 1-Phenyl-2-propanone, phenylacetic
acid and alpha-phenylacetoacetonitrile
125. Since most chemicals are imported into New
Zealand in bulk then repacked within the country in 129. Phenylacetic acid, P-2-P and APAAN are
unmarked containers, the identification of the actual precursors of amphetamine and methamphetamine.
­
source country is often not possible. This applied to the While ­phenylacetic acid and P-2-P are traded legitimately,
majority of incidents, totalling 285 kg, in 2018; 9 per cent, albeit with differences in the extent of their trade, APAAN
respectively, could be traced to China, including Hong is a designer precursor and trade in the substance is
Kong, China (approximately 55 kg), and to the United almost non-existent. N ­ on-scheduled substitutes for P-2-P,
Kingdom (approximately 45 kg). The routing through the ­pre-precursors and designer precursors used in the illicit
United Kingdom indicates the utilization of that country manufacture of amphetamine and methamphetamine are
as a trans-shipment point in an attempt to disguise the discussed in ­subsection (d) below.
actual origin of the ephedrine and avoid detection through
the use of established risk profiles (see also para. 118). Licit trade
130. Between 1 November 2018 and 1 November 2019,
126. In early 2019, France communicated through PICS there were 30 pre-export notifications involving P-2-P,
the dismantling of two small-scale clandestine metham- from five exporting countries to eight importing coun-
phetamine operations in its overseas territory French tries. During the same period, there were no transactions
Polynesia. Approximately 2,000 tablets of pseudoephedrine, involving APAAN, while there were approximately 650
and chemicals indicative of the manufacturing method proposed shipments of phenylacetic acid pre-notified
known as the Birch method, in which anhydrous ammonia through the PEN Online system, from 14 exporting coun-
and lithium metal are used to produce methamphetamine, tries to 47 importing countries and territories.
were seized.
131. In January 2019, the Board inquired about a
(b) Norephedrine and ephedra ­proposed import of 500 kg of P-2-P by a company in
Azerbaijan. The authorities of Azerbaijan eventually
Licit trade stopped the import, as the importing company, which had
127. Between 1 November 2018 and 1 November 2019, a valid import authorization, did not respond to repeated
12 exporting countries notified through the PEN Online inquiries by those authorities about the end use of the
system a total of 210 exports of norephedrine, a substance substance. The authorities of the exporting country were
that can be used in the illicit manufacture of amphetamine. requested to share copies of all relevant documentation
These exports were destined for 35 importing countries about the shipment, as well as copies of administrative
22   INCB REPORT ON PRECURSORS 2019

and commercial documents received from the exporting more than 38,000 litres of P-2-P and 6.5 tons of
company, to enable follow-up investigations in Azerbaijan phenylacetic acid; no further information about the
­
and stop any possible future attempts to import the sources of the chemicals was provided.
­substance to the country.
134. Mexico seized 19,000 litres of P-2-P, the largest
amount ever reported, and approximately 1.3 tons of phe-
Trafficking
nylacetic acid. All of the seizures were made in clandestine
132. Seizure data for P-2-P often reflect only a few large methamphetamine laboratories and, in all of the seizures,
seizures and can therefore fluctuate strongly year-on-year both chemicals were presumed to have been illicitly
(see figure VIII). Compared with the previous year, on manufactured. This is supported by forensic profiling
­
form D for 2018, more countries reported seizures of larger ­analyses, which suggest that in clandestine laboratories in
amounts of the substance. However, in most cases, no Mexico phenylacetic acid is now made by means of a new
information other than the amount seized was provided. process that uses benzyl chloride and sodium cyanide to
This lack of additional information limits the value of produce benzyl cyanide and subsequently phenylacetic
reported seizure data as a means of identifying and address- acid (see para. 145).
ing weaknesses in precursor control, as it remains unclear
whether the P-2-P was diverted from a legitimate source 135. In 2018, notable seizures of phenylacetic acid
and if it was, where that source may have been, or whether were also reported by Myanmar (4,000 kg, in one inci-
the P-2-P was illicitly manufactured from other controlled dent, with a presumed origin in China) and the
precursors or from non-scheduled pre-­ precursors. Netherlands (132 kg, in three incidents). In 2019,
Addressing the two scenarios – diversion from legitimate through PICS, additional incidents involving P-2-P were
sources and illicit manufacture – requires very different communicated by the Netherlands (totalling nearly
approaches. The Board reminds Governments that it is 2,500 litres) and the United Kingdom (totalling 64 kg).
mandatory, pursuant to article 12, paragraph 12, of the While incidents in the Netherlands almost exclusively
1988 Convention, to report information on methods of involved illicit laboratories, suggesting that the P-2-P
diversion and illicit manufacture. was illicitly manufactured, incidents in the United
Kingdom involved airmail s­hipments from China,
including Hong Kong, China.
Figure VIII. Global seizures of P-2-P reported on
form D, 2009–2018
136. On form D for 2018, seizures of APAAN were
reported by eight countries. The largest amount was
40,000 18 reported by Jordan, seized in a “captagon”20 laboratory
35,000 16 where amphetamine was synthesized from benzyl
Number of countries repor�ng

14 ­c yanide, a non-scheduled amphetamine pre-precursor.21

Amount seized (litres)

30,000
12 APAAN and P-2-P were seized from the l­aboratory as
25,000
10 chemical intermediates in the synthesis process that
20,000 started with benzyl cyanide (see para. 146). The findings
8
15,000 illustrate that non-scheduled chemicals and trends in
6
10,000 illicit ­manufacturing methods spread quickly and across
4
regions. Therefore, the Board urges all Governments
5,000 2
to remain alert in regard to the possible use of non-
0 0
scheduled pre-precursors in illicit drug manufacture,
09

10

11

12

13

14

15

16

17

18

to keep themselves up to date and to consult available

20

20

20

20

20

20

20

20

20

20

tools, such as the Board’s limited international special

Amount seized Number of countries repor�ng
surveillance list of non-­ scheduled ­chemicals, and
PICS.

133. Countries in which seizures of P-2-P were effected

at the border often claimed China as the source. This
included a number of countries in Europe, as well as 20
The term “captagon” is used to refer to the product currently
Myanmar, where approximately 3,300 litres of the a­ vailable on the illicit market in countries in the Middle East. The compo-
sition of the product has nothing in common with that of Captagon, a
­substance were seized from an unattended truck that was
pharmaceutical product that became available in the early 1960s and that
parked at the roadside of the Mandalay-Lashio highway ­contained fenethylline.
for some time. Authorities in China reported seizures of 21
E/INCB/2018/4, para. 109.
 III. Extent of licit trade and latest trends in trafficking in precursors   23

137. In addition to Jordan, seven countries in Europe Figure IX. Incidents involving APAAN, APAA, MAPA
reported seizures of APAAN on form D for 2018, sev- and P-2-P methyl glycidic acid
eral of which had previously been communicated ­derivatives ­communicated through
through PICS. Notably, the two largest shipments the Precursors Incident Communication
­intercepted at points of entry had originated in or trans- System, 2012–2019
ited Viet Nam. This included a seizure of 4.4 tons of
45 45
APAAN in the seaport of Varna in Bulgaria and a sei-
40 40
zure of 500 kg at Amsterdam airport in the Netherlands.
35 35
A seizure of 25 kg at the seaport of Antwerp in Belgium

Amount (kilograms)
in May 2019 could also be traced to Viet Nam. INCB 30 30

Number of incidents
calls on the Governments concerned to cooperate 25 25
with each other and the Board to determine the modi 20 20
operandi used to traffic APAAN, and to prevent 15 15
future shipments of the substance, which has been 10 10
under international control since October 2014, from 5 5
reaching illicit laboratories.
0 0

12

13

14

15

16

17

18

a
19
20

20

20

20

20

20

20
138. In March and April 2018, Germany dismantled two

20
of the largest illicit amphetamine laboratories ever encoun- MAPA
APAAN
tered, in a rural area near the border with the Netherlands.
APAA
Both laboratories had produced amphetamine base using P-2-P methyl glycidic acid deriva�ves
P-2-P, which itself had been illicitly manufactured from Number of APAA incidents
APAAN, although a large quantity of other designer pre- Number of APAAN incidents
cursors was also found, such as APAA, as well as designer Number of MAPA incidents
Number of incidents involving P-2-P
precursors of MDMA. All labels on the drums had been methyl glycidic acid deriva�ves
removed. One of the laboratories was determined to have
had a capacity of 150 to 200 litres of amphetamine base a
Data only cover the first 10 months of 2019.
weekly and was estimated to have possibly produced more
than 9 tons of amphetamine since its installation in
January 2018. 140. In 2018, as in previous years, the overwhelming
majority of seizures of these three designer precursors
occurred in European countries. The largest amounts were
(d) Use of non-scheduled substances and seized in the Netherlands, almost exclusively in illicit
other trends in the illicit manufacture laboratories. Seizures of the three substances totalling
­
more than 1 ton were also made in Belgium, Bulgaria,
of amphetamine and
Croatia, Czechia, Denmark, Germany, Portugal and the
methamphetamine United Kingdom, typically at airports or seaports.
Alpha-phenylacetoacetamide, methyl alpha-
141. On form D for 2018, the only seizure outside of
phenylacetoacetate and P-2-P methyl glycidic Europe was reported by authorities in Lebanon and
acid derivatives involved a shipment of nearly 250 kg of the sodium salt of
P-2-P methyl glycidic acid from Hong Kong, China, which
139. APAA, MAPA and P-2-P methyl glycidic acid
was intercepted at the Beirut airport. The Board is also
derivatives are precursors of P-2-P and pre-precursors of
aware of an incident involving MAPA in Australia, as well
amphetamine and methamphetamine. They are designer
as at least one instance of the use of MAPA in a clandestine
precursors that emerged after APAAN was brought under
laboratory in Asia. The Canada Border Services Agency
international control in October 2014 (see figure IX).
reported APAA and MAPA as being among the new
Effective 19 November 2019, APAA was to be included in
­substances identified in 2018.
Table I of the 1988 Convention. The Commission on
Narcotic Drugs is to vote in March 2020 on the Board’s
142. In the first 10 months of 2019, almost 50 seizures of
recommendation to place MAPA under international con-
the three substances were communicated through PICS,
trol. P-2-P methyl glycidic acid derivatives have not as yet
amounting to more than 18 tons. All incidents were
been placed under international control.
­communicated by countries in Europe (see figure X). The
single largest seizure of an inbound shipment in that period
24   INCB REPORT ON PRECURSORS 2019

was a seizure of 2,000 kg of MAPA at a seaport in Slovenia. 145. While use of the nitrostyrene method has ­dominated
However, the Netherlands communicated the largest the illicit manufacture of methamphetamine in Mexico since
number of seizures and the largest total amount seized. In 2016, the latest results of forensic profiling of methampheta-
the 16 incidents for which information about the origin of mine samples of Mexican origin seized in the United States
the shipments was available, China was identified as the by the Special Testing and Research Laboratory of the Drug
country of origin. Reported destination countries included Enforcement Administration of the United States suggest
Belgium, Czechia, France, Germany, the Netherlands, that organized criminal groups in Mexico are now reverting
Poland and the United Kingdom. to phenylacetic acid-based methods (see figure XI). However,
unlike before, ­ phenylacetic acid is now being illicitly
Figure X. Seizures of APAA, MAPA and P-2-P methyl ­manufactured from benzyl chloride and sodium cyanide, via
glycidic acid derivatives communicated by benzyl cyanide intermediate (see para. 146).
countries in Europe through the
Precursors Incident Communication Figure XI. Methods used in the illicit manufacture of
System, in kilograms, 2019 methamphetamine, as determined by the
forensic profiling of methamphetamine
360 samples from the United States of
1,007 250 55
2,000 America and Mexico, 2015–2018
2,000
80

70
Belgium

Czechia 60

France 50
Percentage

Germany
40
Netherlands
30
Slovenia
20
United Kingdom
10
12,933

Note: data only covers the first 10 months of 2019. 0

/1

/2
1

/2

/1

/2

/1

/2
-Q

-Q

18

18
15

16

16

17

17
15

15

20
20

20

20

20

20

20
20

20

Benzaldehyde, nitroethane and

Phenylace�c acid-based methods Nitrostyrene method
1-phenyl-2-nitropropene
143. Benzaldehyde and nitroethane are used in the
Benzyl chloride, sodium cyanide and benzyl
s­ o-called nitrostyrene method to manufacture P-2-P and
subsequently, methamphetamine or amphetamine. cyanide
1-Phenyl-2-nitropropene is the chemical intermediate 146. Several countries reported seizures of non-­scheduled
derived from the reaction between benzaldehyde and chemicals that can be used in the illicit manufacture of
nitroethane and may also be encountered as a starting P-2-P via APAAN or phenylacetic acid. Specifically, there
material in illicit laboratories. were significant seizures of benzyl chloride and benzyl
cyanide,22 versatile precursors of both APAAN and
144. In 2018, the use of the nitrostyrene method, as ­phenylacetic acid, and subsequently P-2-P and a­ mphetamine
­evidenced by seizures of one or more of the above-named or ­ methamphetamine. Significant seizures of benzyl
chemicals, was reported by countries in North America ­cyanide in connection with the illicit manufacture of
(Mexico and the United States) as having been used for the amphetamine were reported by Jordan (9.4 tons seized in
manufacture of methamphetamine, and in Europe (Estonia, an illicit “captagon” laboratory) (see also para. 136),
Germany, Hungary, Russian Federation, and Spain), as Germany (7 tons) and the Netherlands (more than 2 tons).
having been used predominantly for the manufacture of Mexico seized nearly 900 kg of benzyl cyanide in four
amphetamine. Germany reported the detection of benzal-
dehyde and nitroethane in connection with the illicit 22
Benzyl cyanide may also be referred to by its synonym
­manufacture of methamphetamine. phenylacetonitrile.
 III. Extent of licit trade and latest trends in trafficking in precursors   25

methamphetamine laboratories. There is also anecdotal widespread use of the Nagai method or modifications
forensic information indicating that benzyl cyanide is thereof, which use iodine and red phosphorous, or alternate
being used as the starting material to produce APAAN and chemicals such as hypophosphorous acid and phospho-
­subsequently methamphetamine in South-East Asia. The rous acid. Seizures of one or more of these chemicals were
Board encourages all Governments, in particular reported by countries in Africa (Nigeria), Asia (Malaysia),
Governments in East and South-East Asia, to remain North America (United States), Oceania (New Zealand) and
alert with regard to the use of non-scheduled chemicals Europe (Austria, Czechia, Germany, Hungary, Netherlands,
in the illicit manufacture of methamphetamine. Slovakia and Spain). The number of countries in Europe
reporting seizures and the notable amounts seized in some
147. Sweden reported seizures of 6 kg of benzyl chloride, of those countries, such as the Netherlands (more than
a precursor of benzyl cyanide. No significant seizures of 1.5 tons of iodine, 230 kg of red phosphorous and 7,000 litres
sodium cyanide, the chemical needed to convert benzyl of hypophosphorous acid) and Czechia (more than 160 kg of
chloride into benzyl cyanide, were reported to INCB. In the iodine and 135 kg of red phosphorous), have provided
past, such seizures had come to the attention of INCB from ­further evidence of an increase in the illicit manufacture of
the border area between Thailand and Myanmar, however, methamphetamine in Europe, and suggest that such
the actual use of the chemical in the illicit manufacture of ­manufacture may be occurring on a substantial scale.
methamphetamine in that region has not been established.
151. Hydriodic acid, which is another alternate chemical
148. Countries that reported notable seizures of other used in the Nagai method, was reported to have been seized
P-2-P precursors not under international control in 2018 only in small amounts in 2018, for example, in the United
included the Netherlands, where almost 1.5 tons of 2-phe- States, providing further support for the Board’s recom-
nylacetamide, a precursor of phenylacetic acid, were mendation to not place the substance under i­nternational
seized. The United Kingdom intercepted 12 kg of ethyl control under the 1988 Convention. With regard to chemi-
phenylacetate shipped from China. Both chemicals can be cals indicative of the Emde method of illicit methampheta-
used as precursors of phenylacetic acid. mine manufacture, which has long been the predominant
method used in South-East Asia, seizures of key chemicals,
such as thionyl chloride, fell short of the suspected ­capacity
Precursors for the illicit manufacture of
for illicit methamphetamine manufacturing in that
ephedrine and pseudoephedrine ­subregion. In 2018, only Myanmar reported seizures of
149. China continued to report widespread illicit thionyl chloride, a­ mounting to only 16 litres.
­manufacture of ephedrines. After the key starting material,
2-bromopropiophenone, was placed under control 152. Seizures of separation agents, such as tartaric acid,
­nationally in May 2014, the authorities in China observed that are used to increase the potency of methamphetamine
a shift to other non-scheduled chemicals down the synthe- manufactured using P-2-P-based methods have been
sis path, namely 1-phenyl-1-propanone (placed under reported by Mexico regularly since 2009, coinciding with
national control in 2017) or its precursors. The authorities that country’s ban on imports of ephedrine and the
estimated that approximately 97 per cent of the ephedrine ­subsequent shift to the use of P-2-P-based methods in the
and ­ pseudoephedrine in China is made from or via illicit manufacture of methamphetamine. On form D for
2-­bromopropiophenone. Importantly, although the 2018, Mexico reported seizures of almost 6 tons of tartaric
­manufacturing process results in a racemic chemical inter- acid. Other countries that reported seizures of separation
mediate and requires the separation of optical ­isomers, the agents in 2018 or from which the use of such agents are
desired, potent form of d-methamphetamine is obtained known included the Netherlands (875 kg of tartaric acid)
with an optical purity of more than 99 per cent. and China, in connection with the illicit manufacture of
ephedrine (see para. 149).

Other chemicals not under international control

that were seized in relation to the clandestine 2. Substances used in the illicit
manufacture of amphetamine or manufacture of 3,4-methylenedioxy-
methamphetamine methamphetamine and its analogues
150. Other chemicals not under international control but 153. 3,4-MDP-2-P, piperonal, safrole and safrole-rich
frequently reported on form D for 2018 were those associ- oils, and isosafrole are precursors that can be used in the
ated with the illicit manufacture of methamphetamine using illicit manufacture of MDMA and related substances (see
ephedrines-based methods. Reported seizures confirm the annex VIII). Of these four substances, piperonal is the
26   INCB REPORT ON PRECURSORS 2019

most widely traded, while trade in 3,4-MDP-2-P and limited relevance of safrole in the illicit manufacture of
isosafrole is almost non-existent. In 2018, as in previous MDMA, in particular in Europe. An unspecified amount
years, there was little evidence that these four controlled of safrole, along with other chemicals and equipment, was
precursors were being used in the illicit manufacture of found in the first clandestine MDMA laboratory known to
MDMA and related substances to any significant extent. In have been dismantled in the Philippines. Authorities
cases where 3,4-MDP-2-P was seized, it had usually been believe that the laboratory may have also been used as an
illicitly manufactured. By contrast, a number of non- experimental site for new types of amphetamine-type
scheduled substitutes for 3,4-MDP-2-P, often designer stimulants. No seizures of isosafrole were reported on
precursors without any known legitimate uses, such as form D for 2018, nor was any incident involving the sub-
derivatives of 3,4-MDP-2-P methyl glycidic acid, were stance communicated through PICS.
reported to have been seized in notable amounts. They are
discussed in paragraphs 158–159.
(c) Use of non-scheduled substances and
other trends in the illicit manufacture
(a) 3,4-Methylenedioxyphenyl-2- of 3,4-methylenedioxy-
propanone and piperonal methamphetamine and its analogues
Licit trade 158. Over the years, a number of substitute chemicals for
154. Between 1 November 2018 and 1 November 2019, 3,4-MDP-2-P and safrole have emerged, including
16 exporting countries and territories notified the designer precursors that are not usually available off the
­authorities of 47 importing countries and territories of shelf. Of those, derivatives of 3,4-MDP-2-P methyl gly-
more than 670 proposed exports of piperonal amounting cidic acid, namely, the methyl ester and the sodium salt,
to more than 2,600 tons. There were no pre-export notifi- have been the most prevalent, especially in Europe. In
cations for 3,4-MDP-2-P. March 2019, the Commission on Narcotic Drugs decided
to include 3,4-MDP-2-P methyl glycidic acid and its
Trafficking methyl ester in Table I of the 1988 Convention. The deci-
sion was to become effective on 19 November 2019.
155. On form D for 2018, the only notable seizures of
3,4-MDP-2-P were reported by Spain (almost 530 litres)
159. On form D for 2018, the largest seizures of
and the Netherlands (almost 190 litres, in eight incidents).
3,4-MDP-2-P substitutes were reported by the
Aggregate annual seizures of 3,4-MDP-2-P remained
Netherlands, where more than 2.8 tons of the methyl
insignificant in other countries. Quantities of piperonal
ester, and 1.1 tons of the sodium salt, of 3,4-MDP-2-P
seized were insignificant.
methyl glycidic acid were seized. Portugal reported two
seizures of consignments in the customs area of an inter-
(b) Safrole, safrole-rich oils and isosafrole national airport totalling 1.2 tons of the methyl ester. As
with the majority of such consignments, they were sus-
Licit trade pected to have originated in China; one was destined for
156. Between 1 November 2018 and 1 November 2019, Portugal, the other for the Netherlands. Seizures of small
four exporting countries sent 29 pre-export notifications inbound consignments of derivatives of 3,4-MDP-2-P
through the PEN Online system for safrole and safrole- methyl glycidic acid were also made in Belgium, Germany
rich oils to the authorities of 15 importing countries and and the United Kingdom. Seizures of derivatives of
territories. Those notifications concerned a total volume of 3,4-MDP-2-P methyl glycidic acid continued to be made
more than 1,400 litres, including 220 litres in the form of in 2019 (see figure XII) and included the first reported
safrole-rich oils. There were no pre-export notifications incident in Australia. With this new development,
for isosafrole. ­incidents involving these substitutes have now been docu-
mented in Europe, North America, West Asia and
Oceania. The Board is aware that these chemicals are
Trafficking available through online vendors and trading platforms
157. The total global volume of seizures of safrole and and encourages Governments to enforce any applicable
safrole-rich oils reported on form D for 2018 did not regulations to prevent the misuse of the Internet for
exceed 200 litres. The bulk of that volume was seized in a their diversion into illicit channels or, at a minimum, to
single incident in the Netherlands, continuing a trend use such information to generate actionable intelli-
observed over the past several years and reflecting the gence for use in further investigations.
 III. Extent of licit trade and latest trends in trafficking in precursors   27

Figure XII. Seizures of substitutes of 3,4-MDP-2-P of formaldehyde and more than 10.5 tons of ammonium
communicated through the Precursors chloride. Both chemicals were seized in ­clandestine meth-
Incident Communication System, amphetamine laboratories.24
2013–2019
Hydrogen gas
10,000 30
163. On form D for 2018, the Netherlands reported
9,000
25
­seizures of 2 tons of hydrogen gas, which can be used as a
8,000 reducing agent in the illicit manufacture of a number of
Amount seized (kilograms)

7,000 synthetic drugs. Germany also continued to report thefts

Number of incidents
20
6,000 of steel gas cylinders containing compressed hydrogen
5,000 15 gas, albeit in a significantly lower number than in previ-
4,000 ous years. The hydrogen stolen in Germany in 2018
10 amounted to 640 litres, and was stolen from a company
3,000
dealing in construction materials near the border with the
2,000
5 Netherlands. It was presumed to have been used in the
1,000
illicit manufacture of amphetamines.
0 0
2013 2014 2015 2016 2017 2018 2019a
Other substances not under international
Amount seized Number of incidents control
164. As in previous years, substances frequently men-
a
Data only cover the first 10 months of 2019. tioned on form D for 2018 included chemicals associated
with the so-called Leuckart method, which can be used to
manufacture amphetamine and methamphetamine from
P-2-P, or to manufacture MDMA and related substances
3. Other trends in the illicit
from 3,4-MDP-2-P. As in the past, notable amounts were
manufacture of amphetamine-type seized in Europe, including in the Netherlands (9.7 tons of
stimulants formamide and 8,700 litres of formic acid) and Spain
(more than 8.8 tons of formamide and 1,600 litres of
Methylamine and its precursors formic acid), and in North America, notably in Mexico
160. Methylamine is a versatile chemical that is required (more than 4,500 litres of formamide).25
in the illicit manufacture of a number of amphetamine-
type stimulants (e.g., methamphetamine and MDMA) and 165. None of the designer precursors in the form of
new psychoactive substances, as well as ephedrine. ­previously identified masked derivatives of amphetamine-
Seizures of methylamine in the form of both solutions and type stimulants were reported to have been seized in 2018.
hydrochloride salt continued to be reported. However, forensic scientists in Australia identified
­para-tosyl-methamphetamine, another chemically masked
161. On form D for 2018, notable seizures of methyl- methamphetamine, in a sample from a seizure of several
amine were reported by the Netherlands (more than postal consignments originating in China in mid-2017.26
11 tons), Mexico (more than 9,300 litres), and the United
States (1,500 litres). Seizures in Mexico were made in clan- 166. As in previous years, in 2018, several countries
destine methamphetamine laboratories, as in the past. In reported seizures of adulterants used in connection with
the United States, a large proportion of the amount the illicit manufacture of amphetamine-type stimulants.
reported (1,000 kg) was seized for having been in violation Caffeine continued to be one of the most frequently and
of applicable United States trans-shipment regulations. widely reported adulterants. On form D for 2018, Myanmar
Further investigations revealed that the consignee in
Canada had also had a shipment of 1,000 kg seized in 2017 24
Ammonium chloride is also required in the illicit manufacture of
for the same violation.23 heroin (see para. 210), and part of the ammonium chloride seized in
Mexico was found in illicit heroin laboratories.
162. In 2018, notable seizures of chemicals from which
25
Peru seized almost 3.3 tons of formic acid in 2018. Significant
s­ eizures of the chemical have been reported in Peru since 2013, r­ eportedly
methylamine can be manufactured were again reported by in connection with illicit cocaine manufacture.
Mexico. Specifically, authorities seized more than 4,500 litres 26
Michael Collins, Ananta Bhattarai and Helen Salouros, “Another
chemically masked drug: p-tosyl methylamphetamine”, Drug Testing and
23
E/INCB/2018/4, para. 151. Analysis, vol. 10, No. 5 (May 2018), pp. 898–905.
28   INCB REPORT ON PRECURSORS 2019

reported having seized nearly 20 tons of caffeine, in connec- and Herzegovina,28 Chile, China, Colombia and Venezuela
tion with the illicit manufacture of methamphetamine (Bolivarian Republic of) each seized more than 1 ton of
(“yaba”) tablets, Brazil reported having seized more than the substance. Seizures in countries in South America
1.6 tons of caffeine, in connection with the adulteration of were often made in illicit cocaine laboratories. Chile also
cocaine, amphetamines and new psychoactive substances, reported seizures of the substance en route to Bolivia
Malaysia reported seizures of 320 kg of the substance, in (Plurinational State of), while in Bolivia (Plurinational
connection with MDMA, “erimin5” and low-grade heroin, State of) and Colombia, as in previous years, the amount
and Spain reported seizures of 121 kg of the substance. reported seized included administrative seizures following
INCB reminds Governments of the investigative value of which the substance may have been returned to the owner.
monitoring adulterants and cutting agents in order to
trace the laboratories in which drugs are illicitly manu- 169. Colombia reported the dismantling of eight illicit
factured. Governments may also wish to consider taking laboratories involved in the manufacture of potassium
action against adulterants and cutting agents in permanganate in 2018. In the first six months of 2019,
­accordance with article 13 of the 1988 Convention. another four potassium permanganate laboratories were
destroyed and 27 tons of the substance were seized. The
available information thus provides further support for the
B. Substances used in the illicit observation that most chemicals used in the illicit process-
manufacture of cocaine ing of cocaine in South America are either diverted from
legitimate domestic distribution channels or are illicitly
1. Potassium permanganate manufactured, and therefore require national or regional
responses. However, it is still unclear how much potassium
Licit trade permanganate originates from either source. There is also
167. Between 1 November 2018 and 1 November 2019, insufficient understanding of the modi operandi used for
the authorities of 31 exporting countries and territories sent domestic diversion of the substance in countries in South
more than 1,500 pre-export notifications to 128 importing America. INCB therefore reiterates its call to all
countries and territories relating to a total of almost Governments of countries in the region to review their
28,000 tons of potassium permanganate. The main exporter domestic control mechanisms for potassium permanga-
was China, accounting for approximately 20,000 tons, fol- nate and its substitutes and precursors and to devise
lowed by India and the United States, accounting for more strategies to address the situation.
than 3,000 tons each. The main importers were countries in
East and South-East Asia. Imports of the substance by the 170. Small amounts of potassium permanganate were
three coca-producing countries in South America – Bolivia also reported seized in Europe, namely in illicit laborato-
(Plurinational State of), Colombia and Peru – continued to ries in the Netherlands and Spain, where cocaine was
account for a very limited proportion of the total global recovered and refined after smuggling. Such laboratories
amount imported (less than 1 per cent). Imports of the continued to be dismantled in 2019.
­substance by other countries in South America amounted
to approximately 3 per cent (900 tons). None of those coun-
tries exported or re-exported potassium permanganate in
2. Use of non-scheduled substances
any significant amounts. and other trends in the illicit
manufacture of cocaine
Trafficking 171. In 2018, as in previous years, countries in South
168. Potassium permanganate continued to be the prin- America reported seizures of a number of chemicals that
cipal oxidizing agent used in the illicit manufacture of are known for their potential use in connection with illicit
cocaine, and the vast majority of seized cocaine continued cocaine processing and that are under national control in
to be highly oxidized.27 In 2018, 17 countries and territo- those countries. The majority of those chemicals were
ries reported seizures of potassium permanganate totalling reported to have been diverted from domestic distribu-
more than 80 tons. Bolivia (Plurinational State of), Bosnia tion channels. However, INCB notes that a significant
proportion of the seizures were made for administrative
reasons and in response to violations of transport
­regulations. The Board encourages the Governments
27
According to recent results from the Cocaine Signature Program of
the United States Drug Enforcement Administration Special Testing and
Research Laboratory, 100 per cent of the cocaine samples examined, from 28
The circumstances of the seizures were not provided; the substance
2018 seizures in the United States, were highly oxidized or reoxidized. allegedly originated in Slovenia.
 III. Extent of licit trade and latest trends in trafficking in precursors   29

concerned to assess the proportions of seizures that 176. On form D for 2018, as in previous years, significant
were made on the basis of suspected illicit use and those seizures of common acids, bases and solvents not under
made purely for administrative reasons, with a view to international control were reported by countries in South
assessing the effectiveness of relevant control measures, America, in particular the three coca-producing countries,
enhancing the impact of such measures on illicit manu- Bolivia (Plurinational State of), Colombia and Peru, as well
facture and limiting the burden on law enforcement as Ecuador and Venezuela (Bolivarian Republic of). Smaller
and regulatory authorities while still preventing the use yet notable seizures were also reported by some countries
of such chemicals for illicit purposes. situated along cocaine trafficking routes and by countries
representing destination markets, such as those in Europe.
Precursors of and substitutes for potassium In those countries, seizures were mainly made in clandes-
tine laboratories where cocaine was being recovered from
permanganate
the materials in which it was incorporated for smuggling.
172. On form D for 2018, notable seizures of precursors
of potassium permanganate were only reported by 177. While the overall situation with regard to seizures of
Colombia. Specifically, in eight incidents, more than solvents remained largely unchanged, with a wide variety
6.8 tons of potassium manganate, an immediate precur- of acetate solvents having been seized in large amounts,
sor of potassium permanganate, were seized, an increase forensic profiling results suggest a shift away from ethyl
from 1.9 tons in 2017. No seizures of manganese dioxide acetate towards other acetate solvents being used in the
(pyrolusite), a precursor of potassium manganate, were final crystallization step of cocaine manufacture.29 The
reported in 2018. same profiling results also suggest that methyl ethyl ketone,
a chemical under international control, remained the most
173. The Netherlands reported seizures of 25 kg of potas- prevalent solvent used to dissolve the hydrochloric acid in
sium manganate and 15 kg of sodium permanganate, a the crystallization step. However, in the majority of samples
direct substitute for potassium permanganate. analysed, no solvent was utilized for that purpose.

174. Notable seizures of sodium hypochlorite, another 178. Significant seizures of calcium chloride, a chemical
possible substitute for potassium permanganate, were that serves both as a drying agent for solvents and to produce
reported by Peru (almost 14 tons in 8 incidents), Bolivia concentrated hydrochloric acid, continued to be reported on
(Plurinational State of) (4,300 litres in 4 incidents), and form D for 2018. Continuing a trend noted by the Board in its
Argentina (3,700 litres in 51 incidents), although some of previous report on precursors,30 the largest amounts were
those seizures were made for administrative reasons, for seized in Ecuador, totalling nearly 145 tons, an increase from
example, because they lacked the required transport 80 tons in 2017 and 24 tons in 2016. According to the authori-
authorization. ties, the substance is sourced in Peru and smuggled through
Ecuador to Colombia. Seizures in Colombia and the
Other substances not under international control, Plurinational State of Bolivia amounted to, respectively,
and trends in the illicit manufacture of cocaine 75 tons and 30 tons, while Peru seized more than 14 tons, the
175. In addition to requiring an oxidizing agent such as largest amount ever reported. Indications of the use of cal-
potassium permanganate, the processing of cocaine cium chloride for solvent drying were also reported by Chile.
requires a variety of other chemicals, including common
acids, bases and solvents used in the extraction of cocaine 179. Sodium metabisulfite is one of the chemicals
base from coca leaves and for the conversion of cocaine reflecting the increased efficiency of clandestine cocaine
base into hydrochloride. In recent years, a number of other processing. Specifically, it is a reducing agent used to
chemicals have also been encountered in clandestine standardize the oxidation level of cocaine base sourced
cocaine laboratories, including chemicals that help to from various extraction laboratories prior to further pro-
improve the efficiency of the manufacturing process by cessing. In 2018, seizures in amounts greater than 15 tons
reducing the volume of chemicals needed and/or the pro- were reported by Colombia (more than 41 tons in
cessing time, as well as chemicals used to illicitly manufac- 132 incidents, originating in Colombia), the Plurinational
ture ammonia, hydrochloric acid or sulfuric acid. Many of State of Bolivia (nearly 24 tons in 28 incidents, of which
those are common chemicals that can be substituted for two thirds were made in illicit laboratories) and Peru
one another and that are legitimately traded, transported (almost 17 tons in 7 incidents).
and used in large quantities. It was often those chemicals
that were seized for administrative reasons. The majority 29
United States Drug Enforcement Administration Special Testing
of them were sourced domestically. and Research Laboratory, Cocaine Signature Program.
30
E/INCB/2018/4, paras. 169–170.
30   INCB REPORT ON PRECURSORS 2019

180. Of the three coca-producing countries, Colombia C. Substances used in the illicit
and Peru reported the illicit manufacture of a number of
other chemicals needed in cocaine processing. These
manufacture of heroin
included ammonia, hydrochloric acid and sulfuric acid.
1. Acetic anhydride
Specifically, Colombia reported the dismantling of two
illicit laboratories involved in the manufacture of sulfuric 184. Acetic anhydride is a key precursor of heroin and a
acid in 2018. In the first six months of 2019, eight labora- frequently and widely traded chemical that is included in
tories were dismantled and more than 400,000 litres of sul- Table I of the 1988 Convention. Acetic anhydride is required
furic acid were seized. Indications of the illicit manufacture not only in the illicit manufacture of heroin, but also in cer-
of hydrochloric acid were reported by Chile and Peru; the tain P-2-P-based methods used in the illicit manufacture of
illicit manufacture of the substance is also known to have amphetamine and methamphetamine (see annex VIII).
occurred in Colombia. Both Colombia and Peru reported
that all chemical starting materials had been sourced 185. In 2018 and 2019, the number of attempts to divert
domestically. Ecuador reported seizures of nitric acid acetic anhydride from international trade remained low; as
(1,100 litres) made on the basis of its alleged use in the in the past, most of the known cases of diversions of the
illicit manufacture of hydrochloric acid; the substance had substance occurred at the level of domestic trade and
been smuggled on trucks, hidden among other goods. ­distribution. The number of newly initiated or continued
investigations into suspected diversion attempts and
181. On form D for 2018, seizures of chemicals that can ­seizures of acetic anhydride identified since 2016, in par-
be used in the illicit manufacture of ammonia were ticular in Europe and West Asia, has been far from negligi-
reported by Bolivia (Plurinational State of) and Peru and ble. Some of the investigations were unnecessarily delayed,
included urea, ammonium nitrate and ammonium sulfate, took a long time or were inconclusive, which made it pos-
each of which were seized in amounts totalling 1 or more sible for traffickers to continue with their illicit activities, as
tons. In addition, the illicit manufacture of ammonia from illustrated in box 2.
urea is known to have occurred in Colombia.
Licit trade
182. With regard to the size of cocaine processing opera- 186. From 1 November 2018 to 1 November 2019, the
tions, chemical analyses of a large seizure of cocaine that authorities of 25 exporting countries and territories used the
originated in the Nariño coca growing region of Colombia PEN Online system to submit more than 1,700 pre-export
suggest a shift in the traditional small-batch method of notifications regarding shipments of acetic anhydride. The
cocaine processing (typically 1 kilogram at a time) to a shipments were destined for 87 importing countries and ter-
multi-kilogram, high-throughput approach.31 ritories and involved a total of approximately 530 million
litres of acetic anhydride.
183. As with other drugs, seizures of cutting agents
(adulterants and diluents) continued to be reported in 187. In 2019, the authorities of the importing countries
connection with illicit cocaine processing. Cutting is per- objected to approximately 7 per cent of pre-export notifica-
formed at the stage of initial crystallization of cocaine tions related to proposed exports of acetic anhydride, mostly
hydrochloride, either at points along the trafficking route, for administrative reasons. This was less than in the period
or in destination countries before retail-level distribution. 2016–2018, when approximately 10.5 per cent of proposed
Cutting agents seized in notable amounts in 2018 included shipments of acetic anhydride were objected to.
caffeine (reported by Brazil), lactose (Argentina), various
local anaesthetics such as lidocaine, procaine and xylo- 188. In 2019, the Board was informed about a review by
caine (Argentina and Brazil) and phenacetin (Brazil). the authorities of Czechia of the legitimate needs for and
Significant amounts of the same cutting agents were also proposed end use of more than 100,000 litres of acetic
reported by the Netherlands and Spain. Chile reported the anhydride purportedly ordered by a legitimate Czech
dismantling of cutting laboratories. company in a country outside the European Union. Based
on information received from the company, the authorities
had only authorized the import of a portion of the
­proposed amount (less than 20,000 litres). The Board
commends all Governments that exercise the adequate
scrutiny when authorizing imports and exports of acetic
31
Jennifer R. Mallette and others, “Changes in illicit cocaine hydro- anhydride, as well as those that have cooperated with
chloride processing identified and revealed through multivariate analysis
of cocaine signature data”, Science and Justice, vol. 58, No. 2 (March 2018),
each other and the Board to investigate seizures and
pp. 90–97. cases of diversion and diversion attempts.
 III. Extent of licit trade and latest trends in trafficking in precursors   31

Box 2. Examples of ongoing investigations into diversion attempts involving acetic anhydride
Case 1
In mid-2017, on the basis of an unusual pattern observed in pre-export notifications, the Board inquired about the
legitimacy of a pre-notified shipment of 24 tons of acetic anhydride, ordered in a third country by a legitimate importer
located in a State member of the European Union. The investigations revealed that the shipment had been destined
for an end user located in another European Union member State. Owing to the delayed exchange of information and
the lack of coordination among the countries concerned, the investigations gradually ceased. The investigations resumed
in 2019 and it was found that in 2017 the proposed end user had not received the shipment in question. Instead,
companies in other European countries were identified as the likely consignees of the shipment after it had been split
into smaller consignments. To date, it has not been possible to verify whether the split consignments of acetic anhydride
in question had reached those consignees. Owing to the particular circumstances of the case, the possibility that the
acetic anhydride had actually been diverted and “lost” during its delivery cannot be excluded.

Case 2
In July and August 2017, respectively, the competent national authorities of the United Arab Emirates and Iraq objected,
through the PEN Online system, to two shipments of 24 tons and 20 tons of acetic anhydride, proposed to be exported
to the two countries by a particular authorized precursor operator in Poland. In both cases, the shipments were objected
to because the respective competent national authorities of Iraq and the United Arab Emirates had not authorized the
import of the acetic anhydride. However, two years later, the authorities of the United Arab Emirates informed the
authorities in Poland that the proposed importer in the United Arab Emirates had denied having placed an order for
the shipment in question. Nevertheless, the documentary evidence that the Polish authorities collected during the
investigation into the matter in Poland and later shared with their counterparts in the United Arab Emirates had clearly
stated the intention of the proposed importers to purchase acetic anhydride in Poland. This was also the case with
regard to the proposed shipment destined for a company in Iraq. Both shipments were eventually suspended in Poland.
Despite clear indications of attempts by the two companies in Iraq and the United Arab Emirates to import acetic anhy-
dride without the required authorization, the Board has no information as to whether or not the companies in Iraq,
Poland and the United Arab Emirates have concluded, since 2017, any commercial transactions with other vendors or
buyers of acetic anhydride in Poland or elsewhere.

Case 3
In 2019, authorities in Poland launched investigations into the trade activities of an authorized precursor operator in
their country that had been identified as a suspected source of acetic anhydride seized in Afghanistan in September
2017 and in the Netherlands in June 2018. The investigations resulted in the identification of more than 70 tons of the
substance that the Polish company had sold between 2017 and 2018 to several unauthorized companies in five European
Union member States, including the Netherlands, as well as to dubious companies in Poland. Such sales continued
even after the seizure of the substance in Afghanistan. Some of these unauthorized companies, or persons believed to
be associated with them, were known to law enforcement agencies as a result of other criminal investigations, including
drug-related investigations. Despite this evidence, the Polish company in question was still registered with the competent
national authorities as a legitimate precursor operator at the time of writing.

189. The Board also wishes to remind Governments that Board wishes to encourage all users of the PEN Online
the main objective of its queries into objected shipments system to make the best use of the tool, which provides
made to competent national authorities is to verify whether examples of best practices from a number of ­investigations
such shipments were objected to only for administrative into suspected diversion attempts.
reasons, or whether the shipments in question might actu-
ally be diversion attempts. In 2019, INCB shared with Trafficking
Governments a guide comprising practical tips for follow-
190. Of the 21 countries and territories that reported
up investigations into shipments of precursor chemicals
­seizures of acetic anhydride on form D for 2018, six coun-
that were objected to through the PEN Online system. The
tries — China, Georgia, Iran (Islamic Republic of), the
32   INCB REPORT ON PRECURSORS 2019

Netherlands, Pakistan and Turkey— reported seizures of concealment of acetic anhydride among spare car parts
more than 10,000 litres. In total, 188,000 litres of acetic and second-hand cars, followed by the misdeclaration of
anhydride were seized worldwide in 2018, 61,100 litres acetic anhydride at customs as diverse types of liquids
more than in 2017. Poland, followed by China and the used for car maintenance, such as “motor oil”, “windshield
United Arab Emirates, in that order, were the most fre- fluid”, or “antifreeze agent”. For example, in 2018, authori-
quently reported sources – or the last known countries of ties in Poland and Turkey launched investigations into a
departure – of acetic anhydride seized worldwide in 2018 seizure of approximately 450 litres of acetic anhydride in
and 2019. Other countries mentioned included Belgium, Turkey earlier that year. The substance, sourced from a
Czechia and the Netherlands. Polish company co-owned by local and foreign nationals,
was concealed among cargo containing second-hand cars
191. The amounts of acetic anhydride seized in and spare car parts and transported from Poland to
Afghanistan in 2018, as well as in 2019, were much smaller Afghanistan through Turkey. Investigations further
than in previous years. In 2018, 7,364 litres of the substance revealed that the seized shipment was only one of several
were seized, approximately one fifth (20 per cent) of the shipments declared as “spare car parts and second-hand
amount seized in 2017 (37,700 litres). Most of that amount cars” that the Polish company had been sending to con-
could be attributed to a single seizure of a shipment of signees in Afghanistan, Iran (Islamic Republic of) and the
7,000 litres of acetic anhydride that had originated in China United Arab Emirates since 2016, including after the
and had been trafficked through the Islamic Republic of ­seizure of the substance in Turkey in 2018.
Iran. In 2019, only two seizures involving small amounts of
acetic anhydride were communicated by Afghanistan. 195. The authorities of the United Arab Emirates have not
reported on form D any seizures of acetic anhydride since
192. In 2018, 27,680 litres of acetic anhydride were seized 2000, except for a seizure of 4,000 litres in 2009. Despite the
in the Islamic Republic of Iran, 7,000 litres (36 per cent) absence of reported seizures, since 2016, the competent
more than in 2017. At least 14,000 litres were seized in the national authorities of the United Arab Emirates and other
first half of 2019. Shipments of the substance seized in the countries have identified several companies in the United
Islamic Republic of Iran in 2018 and 2019 originated in, or Arab Emirates that have appeared in law enforcement inves-
were reported to have been trafficked through, China (3 tigations either as purported consignees of pre-notified
shipments), the United Arab Emirates (2 shipments), and suspicious shipments involving large amounts of acetic
­
Belgium (1 shipment). The Board notes that the seizure of anhydride, as companies used by traffickers to transport
13,900 litres of acetic anhydride in the port of Bandar seized shipments of acetic anhydride or as companies
Abbas in the Islamic Republic of Iran in May 2019 was responsible for payments for shipments of acetic anhydride
facilitated by a voluntary exchange of information between seized elsewhere. There are also indications that traffickers
the competent national authorities and the private sector. might have used free trade zones in the United Arab
Emirates for the trafficking of precursor chemicals. The
193. During the reporting period, Turkey continued to Board wishes to encourage all countries in which free
be an important transit country for shipments of acetic trade zones exist to review their control measures, includ-
anhydride, believed to be sourced by traffickers in the ing risk profiling of trafficking in precursors, in order to
European Union, then transported to countries in West reduce the risk of such zones being used by criminal
Asia, including Afghanistan, Iran (Islamic Republic of) organizations for their illicit activities.
and Iraq. In 2018, the authorities in Turkey seized 10 con-
signments of acetic anhydride, amounting to 38,569 litres. 196. In Pakistan, seizures of acetic anhydride have
The Board regrets that only 1 of those 10 seizures was fluctuated significantly since 2000. In 2018, Pakistan
­
communicated through PICS. The communicated seizure reported seizures of a total of 19,803 litres of acetic anhy-
involved a shipment of almost 14,000 litres (15 tons) of the dride. Most of that amount, 15,500 litres, suspected of
substance and was believed to have been sourced in the having originated in Poland, could be attributed to a single
Netherlands. While the Government of Turkey provided seizure conducted in the port of Karachi in Pakistan in
on form D for 2017 further information regarding the sus- January 2018. Following that, the authorities of Pakistan
pected origin of the seized acetic anhydride, it did not reported three additional seizures of the substance in 2018,
submit similar information for the seizures conducted in amounting to 4,283 litres. The Board is not aware of any sei-
2018. zures of acetic anhydride in Pakistan in the first 10 months
of 2019. The lack of any recent major seizures of acetic
194. According to information shared through PICS or anhydride in Pakistan (except for the above-mentioned
during case meetings, the most frequently reported modus ­seizure of 15,500 litres) may indicate a sudden change of
operandi used by traffickers continued to be the routes used by criminal organizations for trafficking in the
 III. Extent of licit trade and latest trends in trafficking in precursors   33

substance; however, as this is unlikely, the situation may internal market of the European Union. In that same year,
warrant a further review of the precursor control measures Georgia also appeared in another investigation as a pro-
currently being implemented Pakistan, including the level posed transit country for the trafficking of acetic anhy-
of profiling of trafficking in acetic anhydride. dride from Europe. The Board is also aware of a seizure of
acetic anhydride in the European Union from a truck reg-
197. For the time being, the diversion of acetic anhydride istered in Georgia. Georgia and Azerbaijan further
from international trade involving Pakistan and its subse- appeared in investigations into the suspected misuse of
quent diversion from domestic distribution channels appear online trading companies by acetic anhydride traffickers.
to be unlikely, as only one shipment of acetic anhydride des- Two seizures of acetic anhydride, totalling 13,733 litres,
tined for Pakistan, amounting to approximately 5,600 litres, conducted in the seaport of Poti in Georgia in 2018,
has been pre-notified through PEN Online since 2017. ­further substantiated the appearance of that country on
Suspicions have been raised sporadically by some law the acetic anhydride trafficking map.
enforcement experts about the possible illicit manufacture
of heroin in the country. While these suspicions could, in 200. The Board, in its 2017 report on precursors, alerted
part, be substantiated by past seizures of acetic anhydride, as Governments to the potential misuse of online trading plat-
well as seizures of sizeable amounts of opium and morphine forms by traffickers of precursor chemicals and has since
in the country, suspicions about the possible illicit manufac- then continued to support competent national authorities in
ture of heroin in Pakistan could not be corroborated to date. their efforts to exchange information on investigations into
However, the recent emergence of illicit heroin manufacture the suspected misuse of legitimate online trading platforms
in Europe, despite being at a very low level, proves that such by traffickers of acetic anhydride, in particular those operat-
manufacture can emerge even in countries far away from ing in Europe and Asia. An example of one such investiga-
the regions where opium poppy is illicitly cultivated. The tion is presented in box 3 overleaf.
Board wishes to encourage all countries, including those
neighbouring Afghanistan, to remain vigilant and com- 201. Since 2016, Iraq has been identified as a proposed
municate through PICS, or through Project Cohesion, transit or destination country in at least five follow-up
any incidents that might indicate the emergence of illicit investigations into seizures of acetic anhydride trafficked
heroin manufacture outside countries in which illicit cul- from Europe, conducted in Bulgaria, Iran (Islamic Republic
tivation of opium poppy occurs. of) and Turkey. At least 25,000 litres of the substance
­allegedly destined for Iraq have been seized worldwide
198. The European Monitoring Centre for Drugs and since 2016. The last such seizure, involving 5,400 litres of
Drug Addiction and the European Union Agency for Law acetic anhydride, misdeclared as “soya oil”, was communi-
Enforcement Cooperation (Europol), in the European cated by the Islamic Republic of Iran in November 2018.
Union Drug Markets Report, 2016, provided information
about the emergence of a new trafficking route, the so- 202. Since 2017, the Board has identified several
called Southern Caucasus route, which, in addition to ­suspicious shipments of acetic anhydride that were pre-
being used for trafficking in opiates from the Golden notified through the PEN Online system and were destined
Crescent, was apparently also being used for trafficking in for consignees in Ukraine. Recently, Ukraine was identified
acetic anhydride, as corroborated by a seizure of 2,500 as a possible transit country for a shipment of acetic
litres of an unusual liquid mixture that, in addition to ­anhydride seized in West Asia.
acetic anhydride, contained almost 600 kg of heroin, as
well as smaller amounts of morphine and codeine. The 203. The Governments of a number of countries,
mixture was seized in a port in Batumi, Georgia, in 2014, including Azerbaijan, Georgia, Iraq and Ukraine, are
­
from a lorry that arrived in Georgia from the Islamic encouraged to review any information related to the
Republic of Iran via Azerbaijan. The mixture was purport- apparent involvement of their respective countries in
edly destined for Ukraine and Moldova.32 recently identified cases of diversion and trafficking in
acetic anhydride and to inform the Board of any findings
199. Later in 2017, in the framework of the INCB-led that could assist the Board in further determining any
intelligence-gathering operation “Follow me”, participat- new changes in acetic anhydride trafficking routes.
ing countries identified a suspicious attempt by a Georgian
company to secure supplies of acetic anhydride on the 204. In the past several years, the number of seizures of
acetic anhydride in Central Asia has been low. For example,
32
European Monitoring Centre for Drugs and Drug Addiction and Turkmenistan has not reported on form D any seizures of
the European Union Agency for Law Enforcement Cooperation, EU Drug
Markets Report: In-depth Analysis (Luxembourg, Publications Office of
acetic anhydride since 2000. Uzbekistan last reported
the European Union, 2016), p. 88. ­seizures of acetic anhydride in 2017, when 20 litres of the
34   INCB REPORT ON PRECURSORS 2019

Box 3. Investigations into the suspected misuse of online trading platforms by traffickers
In late 2018, the authorities of India inspected the premises of a company in their country that was regularly using the
services of legitimate online trading platforms to seek potential buyers of acetic anhydride in several countries, including
Afghanistan, Iran (Islamic Republic of), Pakistan and the United Arab Emirates. The company was registered by the
authorities in India as a trader in acetic anhydride. During the inspection of the company premises, inspectors observed
the company’s employees repackaging stocks of acetic anhydride into jerrycans labelled as “motor oil”. The substance
was purportedly destined for a consignee in Afghanistan. The inspection resulted in the seizure of almost 10 tons of
acetic anhydride, the largest seizure of the substance conducted in the county since 2000.
The Board commends the authorities of India for their efforts and the successful conclusion of the case and is pleased
to note that the seizure was facilitated by voluntary cooperation between the authorities of India and the private sector.
The Board also appreciates the sharing of information by the authorities of India with a number of other countries
concerned regarding the suspected misuse of online trading platforms, thereby providing those countries with an oppor-
tunity to verify the legitimacy of proposed transactions involving acetic anhydride at their end. Regrettably, most of the
countries that received that information have not provided any feedback to the authorities of India regarding any
­outcomes of their investigations into the matter.

substance were seized. According to open source media, in Figure XIII. Seizures of acetic anhydride reported
May 2019, the authorities in Kyrgyzstan seized approxi- by States members of the European
mately 100 litres of acetic anhydride, but no further details Union on form D, 2011–2018
are available. Before that, the only reported seizures of the
25,000 5
substance in the country were in 2007 (9 litres) and 2012
(almost 800 litres).
20,000 4

Number of countries repor�ng

Amount seized (litres)

205. The total amount of acetic anhydride seized within

the European Union substantially increased in 2017
15,000 3
(20,400 litres) and 2018 (17,400 litres), compared with the
period from 2011 to 2016 (see figure XIII). In addition,
since 2016, the authorities of countries in the European 10,000 2

Union prevented an unprecedented number of attempts by

traffickers to divert acetic anhydride, primarily from dis- 5,000 1
tribution channels of the internal market of the European
Union. Nonetheless, the amounts of the substance known
0 0
to have been diverted within and/or smuggled from the
16

17

18
11

12

13

14

15

European Union were enough to enable the illicit manu-

20

20

20

20
20

20

20

20

facture of at least 100 tons of heroin in Afghanistan.

Amount seized Number of countries repor�ng

206. The amount of acetic anhydride that was diverted

might also partly explain the emergence of illicit heroin
manufacture in the past three years in some European 207. Backtracking investigations into diversion and
countries, mainly the Netherlands, but also Bulgaria and ­seizures of acetic anhydride linked with European Union
Germany. According to a media report, an illicit heroin countries provided indications of existing links between
laboratory was also identified in Albania in 2019. traffickers of acetic anhydride and persons previously
 III. Extent of licit trade and latest trends in trafficking in precursors   35

known to law enforcement authorities from their involve- 208. The legal requirement stipulated in the
ment in other forms of serious crime, including trafficking 1988 Convention for proving an alleged offender’s intent
in drugs, persons and firearms. The investigations also or knowledge, or more specifically, for producing evidence
provided evidence of the involvement of foreign nationals, showing that the suspect knew that the substance in ques-
including those from West Asian countries, in precursor- tion was to be used in illicit drug manufacture, has some-
related criminal activities in Europe. In addition, the times been perceived as a possible impediment to the
investigations revealed some difficulties in preventing the successful investigation, prosecution and adjudication of
diversion of and trafficking in acetic anhydride (see para. precursor-related crime in practice. Recent accounts of
208 and box 2). The Board appreciates the level of coop- investigations into cases of trafficking in acetic anhydride
eration of the individual countries concerned, especially have confirmed that the understanding of what may con-
Poland, as well as of the European Commission, in iden- stitute proof of intent in practice, in other words, what the
tifying and addressing existing weaknesses in relation to criminal justice system in a country may consider as
European Union legislation on precursors, in terms of acceptable evidence that a suspect knew, or did not know,
both its implementation at the national level and any that a substance was to be used in illicit drug manufacture,
possible deficiencies it may have. Aware that the has led to significant disparities in the outcomes of related
European Commission is currently in the process of prosecutions and, in some jurisdictions, may have even
evaluating the efficiency of European Union legislation affected the ability of law enforcement authorities to fully
on precursors, the Board trusts that any possible loop- investigate precursor-related crime. An analysis of associ-
holes will be addressed and stands ready to assist in the ated legal requirements and examples of approaches taken
evaluation process. in some jurisdictions are provided in box 4.

Box 4. Proof of intent and knowledge in precursor-related crime

Article 3, paragraph 1, subparagraph (a) (iv), of the 1988 Convention requires States parties to the Convention to establish
as criminal offences under their domestic law, when committed intentionally, the manufacture, transport or distribution
of equipment, materials or of substances listed in Tables I and II, knowing that they are to be used in or for the illicit
cultivation, production or manufacture of narcotic drugs or psychotropic substances. Similarly, under subparagraph (c)
(ii), subject to their constitutional principles and the basic concepts of their legal systems, States parties are also
required to criminalize the possession of substances listed in Tables I and II, knowing that they are being or are to be
used in or for the same purposes.

Paragraph 3 of the same article further provides that knowledge, intent or purpose required as an element of an offence
set forth in paragraph 1 may be inferred from objective factual circumstances.

In practice, producing proof of intent or knowledge at the time the offence was committed may be challenging, irrespec-
tive of the evidentiary rules that may apply in a given national legal system. Defendants commonly deny the requisite
intent or degree of knowledge of the relevant elements necessary for the establishment of their conduct as criminal,
yet tribunals must be satisfied, on the basis of admissible evidence, that the defendants possessed the knowledge that
they deny they had in order to reach a verdict.a In order to be admissible, however, such evidence is not required to
be in the form of direct proof, such as a confession or documentary evidence explicitly confirming actual knowledge.b
The Convention does not impose, but explicitly permits, the inference of intent from circumstantial evidence.c

At the same time, the requirement of proving intent in precursor-related crime serves an important purpose. Precursors
are traded and used widely for licit purposes, and criminal responsibility for their diversion into illicit channels must
not be inadvertently extended to bona fide operators without adequate proof.d Care must therefore be exercised by
examining all evidence rigorously and fully while also ensuring that legal requirements are not interpreted in an unduly
narrow way, bearing in mind the objectives of the Convention to prevent the diversion of precursors.
36   INCB REPORT ON PRECURSORS 2019

Box 4. Proof of intent and knowledge in precursor-related crime (continued)

The Convention recognizes, in article 3, paragraph 11, that “the description of offences (…) and of legal defences thereto
is reserved to the domestic law of a Party and that such offences be prosecuted and punished in conformity with that
law”. However, recent examples from various jurisdictions have shown that disparate standards of what may constitute
adequate proof of intent or knowledge at different stages in the investigation and adjudication of precursor-related
crime have sometimes led to vastly different outcomes of similarly constituted cases, and have, in some cases, even
created challenges already at the stage of investigating potential crime. The Board is aware of cases where proof of
intent or knowledge was de facto treated as a requirement for justifying the opening of criminal investigations, which
could not be satisfied and thus may have led to suspicious activity not being investigated fully, ultimately resulting
in impunity for the alleged perpetrators.

In this context, the Board wishes to refer to the Commentary on the 1988 Convention, which acknowledges that a rigor-
ous analysis of “knowledge”, for example, has to address circumstances of “wilful blindness”, where the actor “closes
his eyes to the obvious”; cases of dolus eventualis, where the offender takes an obvious risk; and circumstances in
which any person in the actor’s position would have had the requisite knowledge.e An all too narrow interpretation of
“knowledge”, or of what may constitute acceptable proof of its presence (or absence) in practice, may effectively derail
attempts to hold perpetrators accountable for precursor-related crime.

The Board further wishes to recall that the Convention permits States parties to adopt more strict or severe measures
than those provided by it if, in the party’s opinion, such measures are desirable or necessary for the prevention or
suppression of illicit traffic. For example, Australia amended its criminal laws in 2015 and, applying a system of strict
liability, no longer requires proof of mental elements of the crime such as knowledge or intent to be proven in the case
of persons who engaged in the import or export of “border-controlled precursors” (a category of precursors defined in
Australian law) that have ended up being used in illicit drug manufacture.

In the light of the foregoing discussion, the Board wishes to highlight that the provisions of the Convention provide
sufficient flexibility for States parties to adopt national criminal legislation on precursor-related offences in a way that
meets minimum international requirements yet remains responsive to the requirements of their respective national legal
systems and the realities on the ground. Even without necessitating changes in legislation, criminal procedure or
­evidentiary rules, criminal justice practitioners at all levels can contribute to curbing impunity for precursor-related crime
by being mindful of their interpretation and application in practice of existing laws in line with the objectives of the
Convention and the safeguards and allowances built into it.

  a See also the Commentary on the 1988 Convention, para. 3.97.
  b Ibid., para. 3.98.
  c Ibid., para. 3.100.
  d Ibid., para. 3.38.
  e Ibid., para. 3.97.

209. Despite the significant need for acetic anhydride in 2. Use of non-scheduled substances
the illicit manufacture of heroin, the number of seizures of
and other trends in the illicit
the substance in Colombia, Mexico and Myanmar has
been low for many years. Although Mexico seized sizeable manufacture of heroin
amounts of acetic anhydride in the past, those seizures 210. The illicit manufacture of heroin requires, in addi-
were likely linked with the manufacture of synthetic drugs tion to acetic anhydride, a variety of other common chem-
rather than heroin. icals not under international control, in particular
chemicals used in the extraction of morphine from opium.
One of the most frequently encountered of those
 III. Extent of licit trade and latest trends in trafficking in precursors   37

chemicals is ammonium chloride. Afghanistan, where the D. Substances used in the illicit
chemical is under national control, has, since 2008, regu-
larly reported seizures of ammonium chloride, albeit in
manufacture of other narcotic
widely varying amounts, ranging from just 350 kg in 2009 drugs and psychotropic
to almost 45.5 tons in 2016. Seizures in 2018 amounted to substances
approximately 2.5 tons.
1. Ergot alkaloids and lysergic acid
211. In addition to the non-scheduled chemicals used in 214. On form D for 2018, seizures of the three p ­ recursors
the extraction of morphine from opium, there are also of lysergic acid diethylamide, ergometrine, ergotamine
non-scheduled acetylation agents that can be substituted and lysergic acid, were reported in all regions except Africa
for acetic anhydride in the conversion of morphine to and Oceania. As in previous years, ­ aggregated annual
heroin, although actual seizures of substitutes for acetic ­seizures of ergot alkaloids, namely ergotamine, reported
anhydride have been rare. The acetylation agent most fre- by individual countries were typically small, not exceeding
quently seized in this context is acetyl chloride. It has 150 grams; the seizures were mostly made for administra-
important legitimate applications; however, it is more tive reasons. China reported seizures of almost 450 grams
­hazardous to handle and use than acetic anhydride because of ergometrine. Where the origin was known, it was
it is corrosive, strongly irritating to the eyes, nose and skin domestic, within the country where the seizure was made.
and reacts violently with water. Seizures of lysergic acid were reported by the Russian
Federation (2 kg) and the United States (nearly 600 grams),
212. In 2018, notable seizures of acetyl chloride were however, no additional ­information was provided.
reported by the Islamic Republic of Iran and the United
Arab Emirates. The first seizure occurred in the Jebel Ali
seaport in Dubai, United Arab Emirates, and involved
N-Acetylanthranilic acid and
2. 
almost 2,800 litres of the substance. The contraband had anthranilic acid
been concealed among other legitimate commodities and 215. The situation regarding the illicit manufacture of
had been destined for a consignee in the Islamic Republic methaqualone remained unchanged in 2018 in comparison
of Iran that could not be located in the country. The second with 2017 and previous years: no instances of illicit manu-
seizure involved nearly 20,000 litres of acetyl chloride and facture of the substance were reported. However, South
was conducted in the port of Bandar Abbas in the Islamic Africa reported having stopped three incoming shipments
Republic of Iran, only a few days after the seizure in the totalling more than 64 tons of acetanthranil, a possible
United Arab Emirates. The substance had been destined precursor of methaqualone that is not under international
for a consignee in Afghanistan. The seizures may indicate control. The shipments were detected by sniffer dogs, but it
partial changes in the modus operandi used in trafficking remained unclear why they were stopped.
in heroin precursors. Countries in West Asia where acetyl
chloride is under national control include Afghanistan 216. The largest seizures of methaqualone precursors
and Pakistan. under international control were reported by Myanmar,
the first such seizures to be reported by the country. They
213. The Board wishes to remind Governments that amounted to 1,000 litres of N-acetylanthranilic acid and
both ammonium chloride and acetyl chloride are 2.1 tons of anthranilic acid, as well as 2,800 litres of the
included in the limited international special surveillance latter substance in solution form. In all instances, the
list of non-scheduled substances owing to their possible seized substances had allegedly originated in China. No
use in the illicit manufacture of heroin. In the light of further information was provided that could help to put
the significant seizures of acetyl chloride in 2018, the these seizures into context. Circumstantial information
Board further encourages countries, in particular in was also not provided in the case of Mozambique, which
West Asia, to remain vigilant against attempts to reported instances of domestic diversion and seizures of
divert and smuggle acetyl chloride through the region 83 litres of N-acetylanthranilic acid.
and to communicate any seizures of the substance
through PICS. Seizures should be duly investigated to 3. Precursors of fentanyl, fentanyl
prevent future trafficking in the substance involving
the same companies.
analogues and other synthetic opioids
Licit trade
217. In the two-year period following the international
scheduling of the two precursors of fentanyl, NPP and
ANPP, as at 1 November 2019, 31 pre-export notifications
38   INCB REPORT ON PRECURSORS 2019

had been sent for NPP and 24 for ANPP by seven export- 220. During 2018, it also became apparent that traffick-
ing countries to 21 importing countries. Amounts larger ers had started to seek alternatives to NPP and ANPP:
than those required for limited research and analytical
purposes were proposed for import into a number of (a) In September 2018, India dismantled the first
countries known to manufacture fentanyl legitimately, illicit fentanyl laboratory discovered in its territory.
including Brazil, Germany, Slovakia, South Africa and the Approximately 11 kg of fentanyl were recovered; the fentanyl
United States. Moreover, at least 20 countries and territo- had been synthesized from non-scheduled pre-­precursors
ries that provided such information voluntarily explicitly via NPP and subsequently ANPP;
stated on form D for 2018 that they had no need for either
NPP or ANPP, or only needed the substances for limited (b) Between mid-2018 and mid-2019, INCB became
research and laboratory analytical purposes. Among those aware of at least 30 incidents involving 4-AP, a fentanyl
countries was Mexico, which had declared on several other pre-precursor not under international control (see also
occasions that there was no legitimate manufacture of para. 60) that was included in the limited international
­fentanyl in the country. special surveillance list. All of the incidents occurred in
Mexico and involved amounts between 0.3 kg and 1.8 kg,
218. Belgium and India reported having stopped ship- and had originated in either China, including Hong Kong,
ments of NPP in 2018. Nevertheless, INCB has become China, the Netherlands or Singapore. A significantly larger
aware of exports in 2018 of NPP from India that lacked the consignment of 4-AP was intercepted in August 2019 at
required no-objection certificates, i.e., that were effected the port of Lázaro Cárdenas in Mexico, involving 275 kg of
without the knowledge of the competent national authori- the substance among bags of calcium chloride amounting
ties, even though NPP and ANPP have been under to a total weight of 23 tons;
national control in India since 28 February 2018. Although
the authorities in India made an arrest and are investigat- (c) Other alternatives to NPP and ANPP not under
ing the incidents, which allegedly involved the same international control that were reported as having been
modus operandi, INCB has determined that, in at least encountered included precursors and chemical intermedi-
one instance involving 400 kg of the substance, the con- ates used in the synthesis of fentanyl by means of the so-
signee in Europe was legitimate and authorized to import called Janssen method, the originally patented method of
NPP and ANPP. The Board reminds all Governments fentanyl manufacture, as well as chemically masked fenta-
that NPP and ANPP are included in Table I of the 1988 nyl pre-precursors (such as t-BOC 4-AP); such chemical
Convention, thus consignments containing those sub- masking is a modus operandi also seen in relation to pre-
stances require the sending of pre-export notifications cursors of other types of drugs;33
prior to their export. The Board furthermore encour-
ages Governments to put the necessary systems in place (d) In June 2019, authorities in Mexico dismantled a
nationally to ensure that their competent national clandestine laboratory site in which a variety of controlled
authorities are informed of any planned export, that the and non-controlled fentanyl precursors and pre-­precursors,
manufacture and distribution of NPP and ANPP are but no end products, were found. Authorities believe that
adequately monitored, and that all diversions and the site had been used to experiment with the synthesis of
attempted diversions are fully investigated with a view NPP and ANPP from their precursors. If substantiated, the
to gathering relevant intelligence and preventing future purpose of the laboratory, together with border seizures of
diversions using the same modus operandi. fentanyl pre-precursors, may also indicate a shift from traf-
ficking in fentanyl precursors to their possible manufacture
Trafficking within Mexico;
219. On form D for 2018, four countries reported sei-
(e) Results from forensic impurity profiling of
zures of either NPP or ANPP. The largest amount (275 kg)
samples of fentanyl seized in the United States in 2018
was reported by the United States, which also reported the
suggested that the Janssen method, which does not rely
dismantling of two fentanyl laboratories. In addition,
on NPP and ANPP, had become the predominant synthe-
France communicated through PICS one incident
sis method; 70 per cent of the powder exhibits analysed
­involving the seizure of approximately 0.5 kg of ANPP in a
and 52 per cent of the tablet exhibits analysed supported
clandestine laboratory. The substance was allegedly
this conclusion.
ordered in China on the darknet. France also communi-
cated two additional incidents that occurred in June and
July 2019 involving a few grams of ANPP smuggled from
the United States through the postal system. 33
E/INCB/2018/4, box 5.
 III. Extent of licit trade and latest trends in trafficking in precursors   39

221. The Canada Border Services Agency reported a E. Substances not listed in Table I or
number of potential precursors of fentanyl and of fentanyl
analogues among the new substances identified in 2018. In
Table II of the 1988 Convention
fact, five out of the seven newly identified fentanyl-related that are used in the illicit
substances can be classified as precursors; all of them are manufacture of other narcotic
known chemical intermediates used in the synthesis of the
respective fentanyls or are their masked analogues. In June
drugs and psychotropic substances
2019, the Royal Canadian Mounted Police seized an or substances of abuse not under
unspecified amount of aniline, a chemical central to the international control
synthesis of various fentanyls by different synthesis routes,
yet also widely used in legitimate industries. Aniline is 1. Precursors of gamma-hydroxybutyric
included in the limited international special surveillance acid
list of non-scheduled substances because of its possible use
in the illicit manufacture of fentanyls. 224. Seizures of GBL continued to be reported on
form D for 2018, typically, as in the past, by countries in
222. Several of the above-mentioned developments Europe. Amounts ranged from less than 1 litre (reported
appear to be the result of tightened controls in China. by Italy) to more than 27,500 litres (reported by Lithuania).
The Board welcomes the measures taken by China in According to the Australian Criminal Intelligence
the spirit of shared responsibility. It also notes the Commission, 22 clandestine laboratories manufacturing
generic approach taken by Canada in controlling some GHB and/or GBL were detected in Australia in the
precursors of fentanyls (see para. 24). Other countries period 2017–2018, an increase of 100 per cent compared
where additional precursors of fentanyls, specifically with the previous reporting period.35 Outside Europe, only
­precursors of 3-methyl fentanyl, are under national con- the United States reported seizures of GBL. Hungary and
trol include Belarus and the Russian Federation, which Spain were the only countries to have reported seizures of
imposed such control in response to earlier outbreaks of 1,4-butanediol, a precursor of GBL and a pre-precursor of
misuse of those substances.34 GHB, on form D for 2018.

223. The Board is concerned that information about the

2. Precursors of new psychoactive
sources of non-medical fentanyls and their precursors is
still limited. The Board is also concerned that Governments substances, including substances
are unable to quickly address shifts to non-scheduled pre- recently scheduled under the Single
precursors, in particular in cases where those substances Convention on Narcotic Drugs of
have legitimate uses, and reminds Governments, at a
1961 or the Convention on
minimum, to cooperate with each other and with the
Board in exchanging actionable information, preferably Psychotropic Substances of 1971
through PICS. The Board also wishes to remind 225. On form D for 2018, a number of European coun-
Governments of the updated limited international tries continued to report instances involving precursors of
­special surveillance list, which includes a number of new psychoactive substances and of recently scheduled
chemicals used in the illicit manufacture of fentanyls substances. Frequently reported chemicals included:
and highlights those for which INCB is not aware of any
legitimate use. 2-Bromo-4’-methylpropiophenone, a mephedrone
• 
precursor, which was seized in France, the Netherlands
and Belgium (in descending order of amounts seized).
Destination countries included the Netherlands,
Spain and the United Kingdom. Where information
about the origin was provided, China was identified
as the suspected country of origin. Seizures in all
countries totalled 60 kg.

34
Information about pre-precursors and other chemicals under
national control is available to competent national authorities as part of
the information package on the control of precursors provided on the 35
Australian Criminal Intelligence Commission, Illicit Drug Data
Board’s secure website. Report 2017–18 (Canberra, July 2019).
40   INCB REPORT ON PRECURSORS 2019

2,5-Dimethoxybenzaldehyde, a precursor for

• 
2,5-dimethoxyamphetamine (DMA), brolamfetamine IV. Article 13 of the
(DOB) and the 2C-series of controlled psychotropic
substances, as well as for new psychoactive substances,
1988 Convention as
reported by the Netherlands (5 kg) and Belgium
(1 kg).
a complementary
4-Methoxy-P-2-P, a precursor of para-methoxy-
• 
tool in addressing
alpha-methylphenethylamine (PMA) and para- illicit drug
methoxymethylamphetamine (PMMA), reported by
Spain (52 kg). manufacture
226. Through PICS, incidents involving 2-bromo-
4’-chloropropiophenone, a precursor of various 4-chloro- 229. The clandestine manufacture of narcotic drugs and
substituted cathinone derivatives, such as 4-CMC psychotropic substances, new psychoactive substances and
(clephedrone), were communicated. Luxembourg seized precursors is not possible without the input of chemicals,
500 kg of the substance in August 2018. The consignment materials and equipment. While the control of chemicals
was confiscated because both the supplier and the con- has long been a focus of the authorities worldwide, pursu-
signee were already known in connection with shipments ant to the provisions in article 12 of the 1988 Convention,
of other precursors of new psychoactive substances. It much less attention has been given to equipment and
originated in India, transited Qatar, Luxembourg and materials and article 13 of that Convention, which pro-
Germany and was destined for a consignee in Poland. A vides a basis for international action and cooperation in
consignment of 300 kg of the substance was confiscated by such control efforts (see box 5).
customs authorities in Germany in December 2018. The
suspected destination was Poland. In April 2018, customs 230. Concern about the use of equipment, including
authorities in Czechia communicated a seizure of a con- ­tableting machines, specialized glassware and other essen-
signment of 100 kg, which had originated in India and was tial laboratory equipment, in illicit drug manufacture is not
destined for Czechia. new, but the spread of fentanyl-related substances and other
synthetic opioids, with their often high potency and their
227. Incidents involving precursors of new psychoactive role in fatal overdose cases in some parts of the world, has
substances, in particular synthetic cathinones, also contin- raised new concerns among Governments and the Board.
ued to occur and be communicated through PICS in 2019,
by the Netherlands (120 kg) and Czechia (575 kg). Open 231. As early as 1998, the General Assembly specifically
media sources referred to a seizure of nearly 2.5 tons of requested national authorities to monitor sales of laboratory
2-bromo-4’-methylpropiophenone in an illicit laboratory equipment, pursuant to article 13 of the 1988 Convention.36
or warehouse in Taiwan Province of China. In 2002 and 2003, the Equipment Working Group of Project
Prism convened two meetings in The Hague, Netherlands,
228. The Board commends countries that voluntarily and Bangkok to discuss the matter. As a tangible result, in
report seizures of precursors of new psychoactive sub- 2004, the Europol Illicit Laboratory Comparison System was
stances and substances recently scheduled under the established. In 2010, the Inter-American Drug Control
1971 and 1961 Conventions, as such reporting helps to Commission developed a concept paper on the regulation of
identify emerging trends and establish links between equipment used in the illicit manufacture of synthetic drugs.
cases, which often involve both scheduled and non- Calls to initiate equipment monitoring and investigations
scheduled chemicals. To make the best possible use of into seizures and cases of diversion or smuggling of essential
available information and intelligence, all Governments equipment have since been made on several occasions, most
are encouraged to communicate relevant incidents recently in March 2019, by the Commission on Narcotic
through PICS in real time. Drugs in its resolution 62/4.

232. The resolution calls on Governments to increase the

operational use of article 13 and take appropriate measures
to prevent trade in and the diversion of equipment used in

36
See General Assembly resolution S-20/4,which sets out the Action
Plan against Illicit Manufacture, Trafficking and Abuse of Amphetamine-
type Stimulants and Their Precursors.
 IV. Article 13 of the 1988 Convention as a complementary tool in addressing illicit drug manufacture   41

Box 5. Article 13 of the 1988 Convention

Article 13 of the 1988 Convention requires the parties to take such measures as they deem appropriate to prevent
trade in and the diversion of materials and equipment for the illicit production or manufacture of narcotic drugs and
psychotropic substances and to cooperate to this end.

Read together with article 3, paragraph 1, subparagraph (a) (iv), of the 1988 Convention, article 13 makes it manda-
tory for parties to establish as criminal offences under domestic law, when committed intentionally, the manufacture,
transport or distribution of equipment.a These provisions relate not only to equipment used for illicit laboratories
within a party’s territory, but also to equipment that is smuggled out of or exported from the party’s territory to
other countries and used in illicit laboratories in those countries (see also para. 13.3 of the Commentary on the
1988 Convention).

  a These provisions are extended to the possession of equipment (art. 3, para. 1, subpara. (c) (ii)). Article 3, paragraph 1, subparagraphs (a) (v)
and (c) (iv) further extend the provisions on criminalization to the organization, management or financing of any of these offences, and to participation
in, association or conspiracy to commit, attempts to commit, and facilitating the commission of any of the offences established in accordance with
article 3.

illicit drug manufacture by enacting national legislation to Figure XIV. Schematic overview of illicitly
implement that article. The resolution also encourages ­manufactured tablets, by drug
INCB to provide guidelines on the most effective ways to and region
prevent the diversion of materials and equipment in the
context of article 13.

233. In order to get an overview of the nature and extent Counterfeit/fake

synthetic opioids
of equipment-related incidents worldwide, with a view to Meth (wy),a MDMA,
subsequently prioritizing global approaches to countering counterfeit/fake
benzodiazepines
the supply of equipment for illicit purposes, the INCB
Precursors Task Force coordinated a global survey among
MDMA
focal points for Project Prism, Project Cohesion and Counterfeit/fake
tramadol
Project Ion in 2018. The 40 responses received suggested
MDMA, counterfeit/
that most reported incidents were seizures (not suspicious fake benzodiazepines
Fake captagon
transactions) that typically involved commercially pro-
duced (not custom-made) equipment, and that the seized
equipment was mostly new (not second-hand). The survey
also showed that few countries have in place any regula-
tions, monitoring requirements or cooperation arrange- a
Illicitly manufactured methamphetamine tablets in South-East
ments with industry for reporting suspicious transactions Asia are typically imprinted with the code “wy”.
in international trade or domestic distribution. Similarly, Note: Arrows are illustrative and do not represent flows of s­ ubstances,
few countries had ever done any equipment-related back- equipment or materials to any specific country.
tracking investigations, nor did they have the capacity to
do so.
235. Statistics about seizures of essential equipment are
234. In terms of prioritizing essential equipment, the not generally available. Where they are, such as in Australia
survey results suggested that it might be useful to focus and the United States, they focus on tableting and encap-
initially on tableting and encapsulating machines and sulating machines, and have indicated an increase in
related punches and dies, the use of which in illicit drug ­seizures in recent years (see figures XV and XVI).
manufacture is a global problem with regional differences
(see figure XIV).
 42   INCB REPORT ON PRECURSORS 2019

Figure XV. Seizures of tableting machines in 236. The Board believes that article 13 is a valuable
Australia, 2008–2018 ­complementary tool in addressing illicit drug manufacture.
However, it is currently underutilized. To assist Governments
60
in increasing the use of article 13 and preventing specialized
equipment from reaching illicit laboratories, the Board
50
­conducted the following activities in 2019:
Number of machines seized

(a) The convening of an expert group meeting on

40
the matter with a view to developing mechanisms and
28 concrete operational activities to prevent and investigate
30 60
57
20
the diversion of specialized equipment for illicit purposes
in the context of article 13 of the 1988 Convention;
20 34
20 No data available (b) The launch of an intelligence-gathering activity
31
26 related to tableting and encapsulating machines;
10 19
17
13 (c) The establishment of a web-based repository of
7
0 3 existing national approaches to the implementation of
article of the 1988 Convention at the national level;
0a
20 9

20 1

20 2

20 3

20 4

20 5

20 6

20 7

8
/0

/1

/1

/1

/1

/1

/1

/1

/1
/1
08

10

11

12

13

14

15

16

17
09

(d) The preparation of practical guidelines on the

20

20

Repor�ng period implementation of article 13, pursuant to Commission on

Narcotic Drugs resolution 62/4; the guidelines were to be
Table�ng machines (border seizures)
launched at the sixty-third session of the Commission, in
Table�ng machines (domes�c seizures)
March 2020;
Encapsulators (domes�c seizures)
(e) A number of measures to enhance international
Source: Australian Criminal Intelligence Commission, Illicit Drug cooperation in equipment-related cases, including pro-
Data Report, 2016–17 and reports from previous years.
moting the use of PICS for the exchange of intelligence
a
On 1 March 2010, tableting machines became a prohibited import
in accordance with the Customs (Prohibited Imports) Regulations 1956 and information about equipment incidents;
of Australia.
(f) Partnerships with relevant entities, such as the
World Customs Organization, to establish harmonized
Figure XVI. Seizures of tableting machines by the system codes for essential equipment, and Europol, to
United States Customs and Border explore synergies between PICS and the Europol Illicit
Protection, 2014–2019 Laboratory Comparison System for global benefit.

237. Building on the activities initiated in 2019, the

400 Board encourages Governments to consider taking the
­following actions:
350
(a) Raise the awareness of competent authorities,
300 industries and related sectors about the risk of various
Number of machines seized

types of equipment being utilized for the illicit manufac-

250 ture of drugs by improving the understanding of the use of
such equipment and the related diversion methods;
200
(b) Initiate investigations into seizures and cases
150 involving the diversion or smuggling of essential equip-
ment, with a view to tracking it back to the source in order
100
to prevent continued illicit activity, and communicate the
details of those seizures and backtracking investigations in
50
real time, preferably through PICS.
0
238. The Board looks forward to enhanced global coop-
2014 2015 2016 2017 2018 2019a eration among Governments and between Governments
and INCB in the context of article 13 and stands ready to
a
Up to and including August 2019; data may also include seizures of
punches and dies. Years are fiscal years.
support Governments to that end.
 Glossary  43

Glossary
In the present report, the following terms and definitions have been used:

chemical intermediate A chemical generated during a multi-step synthesis process that is normally not isolated
but immediately consumed in the next synthesis step. Stable chemical intermediates can
be isolated and have been encountered as purpose-made substitute chemicals for
­controlled precursors

designer precursor A
 close chemical relative of a controlled precursor that is purpose-made to circumvent
controls and usually does not have any recognized legitimate use

diversion The transfer of substances from licit to illicit channels

immediate precursor A precursor that is generally only one reaction step away from the end product

industrial-scale laboratory A
 laboratory manufacturing synthetic drugs in which oversized equipment and/or
glassware that is either custom-made or purchased from industrial processing sources
and/or that uses serial reactions is used and in which significant amounts of drugs are
produced in very short periods of time, the amount being limited only by the need for
access to precursors and other essential chemicals in adequate quantities and for the
logistics and workers to handle large amounts of drugs and chemicals

pharmaceutical preparation A
 preparation for therapeutic (human or veterinary) use in its finished dosage form that
contains precursors present in such a way that they can be used or recovered by readily
applicable means; such preparations may be presented in their retail packaging or in
bulk

seizure P
 rohibiting the transfer, conversion, disposition or movement of property or assuming
custody or control of property on the basis of an order issued by a court or a competent
authority; it may be temporary or permanent (i.e., confiscation); different national legal
systems may use different terms

stopped shipment A
 shipment permanently withheld because reasonable grounds exist to believe that it
may constitute an attempted diversion, as a result of administrative problems or because
of other grounds for concern or suspicion

suspended shipment A
 shipment temporarily withheld because of administrative inconsistencies or other
grounds for concern or suspicion, for which clarification of the veracity of the order and
resolution of technical issues are required before the shipment may be released

suspicious order An order (or transaction) of questionable, dishonest or unusual character or condition,
(or suspicious transaction) for which there is reason to believe that a chemical that is being ordered, imported or
exported or is transiting a country or territory is destined for the illicit manufacture of
narcotic drugs or psychotropic substances
 Annex I  45

Annex I

Parties and non-parties to the United Nations

Convention against Illicit Traffic in Narcotic Drugs and
Psychotropic Substances of 1988, by region, as at
1 November 2019
Note: The date on which the instrument of ratification or accession was deposited is indicated in parentheses.

Non-party to the
Region Party to the 1988 Convention
1988 Convention
AFRICA Algeria Eswatinia Equatorial Guinea
(9 May 1995) (8 October 1995)
Angola Ethiopia Somalia
(26 October 2005) (11 October 1994)
Benin Gabon South Sudan
(23 May 1997) (10 July 2006)
Botswana Gambia
(13 August 1996) (23 April 1996)
Burkina Faso Ghana
(2 June 1992) (10 April 1990)
Burundi Guinea
(18 February 1993) (27 December 1990)
Cabo Verde Guinea-Bissau
(8 May 1995) (27 October 1995)
Cameroon Kenya
(28 October 1991) (19 October 1992)
Central African Republic Lesotho
(15 October 2001) (28 March 1995)
Chad Liberia
(9 June 1995) (16 September 2005)
Comoros Libya
(1 March 2000) (22 July 1996)
Congo Madagascar
(3 March 2004) (12 March 1991)
Côte d’Ivoire Malawi
(25 November 1991) (12 October 1995)
Democratic Republic of the Congo Mali
(28 October 2005) (31 October 1995)
Djibouti Mauritania
(22 February 2001) (1 July 1993)
Egypt Mauritius
(15 March 1991) (6 March 2001)
Eritrea Morocco
(30 January 2002) (28 October 1992)
46   INCB REPORT ON PRECURSORS 2019

Non-party to the
Region Party to the 1988 Convention
1988 Convention
Mozambique South Africa
(8 June 1998) (14 December 1998)
Namibia Sudan
(6 March 2009) (19 November 1993)
Niger Togo
(10 November 1992) (1 August 1990)
Nigeria Tunisia
(1 November 1989) (20 September 1990)
Rwanda Uganda
(13 May 2002) (20 August 1990)
Sao Tome and Principe United Republic of Tanzania
(20 June 1996) (17 April 1996)
Senegal Zambia
(27 November 1989) (28 May 1993)
Seychelles Zimbabwe
(27 February 1992) (30 July 1993)
Sierra Leone
(6 June 1994)

Regional total
51 3
54

AMERICAS Antigua and Barbuda Dominica

(5 April 1993) (30 June 1993)
Argentina Dominican Republic
(10 June 1993) (21 September 1993)
Bahamas Ecuador
(30 January 1989) (23 March 1990)
Barbados El Salvador
(15 October 1992) (21 May 1993)
Belize Grenada
(24 July 1996) (10 December 1990)
Bolivia (Plurinational
Guatemala
State of)
(28 February 1991)
(20 August 1990)
Brazil Guyana
(17 July 1991) (19 March 1993)
Canada Haiti
(5 July 1990) (18 September 1995)
Chile Honduras
(13 March 1990) (11 December 1991)
Colombia Jamaica
(10 June 1994) (29 December 1995)
Costa Rica Mexico
(8 February 1991) (11 April 1990)
Cuba Nicaragua
(12 June 1996) (4 May 1990)
 Annex I  47

Non-party to the
Region Party to the 1988 Convention
1988 Convention
Panama Suriname
(13 January 1994) (28 October 1992)

Paraguay Trinidad and Tobago

(23 August 1990) (17 February 1995)
Peru United States of America
(16 January 1992) (20 February 1990)
Saint Kitts and Nevis Uruguay
(19 April 1995) (10 March 1995)
Venezuela (Bolivarian
Saint Lucia
Republic of)
(21 August 1995)
(16 July 1991)
Saint Vincent and the Grenadines
(17 May 1994)

Regional total
35 0
35

ASIA Afghanistan Israel

(14 February 1992) (20 March 2002)
Armenia Japan
(13 September 1993) (12 June 1992)
Azerbaijan Jordan
(22 September 1993) (16 April 1990)
Bahrain Kazakhstan
(7 February 1990) (29 April 1997)
Bangladesh Kuwait
(11 October 1990) (3 November 2000)
Bhutan Kyrgyzstan
(27 August 1990) (7 October 1994)
Brunei Darussalam Lao People’s Democratic Republic
(12 November 1993) (1 October 2004)
Cambodia Lebanon
(2 April 2005) (11 March 1996)
China Malaysia
(25 October 1989) (11 May 1993)
Democratic People’s Republic of
Maldives
Korea
(7 September 2000)
(19 March 2007)
Georgia Mongolia
(8 January 1998) (25 June 2003)
India Myanmar
(27 March 1990) (11 June 1991)
Indonesia Nepal
(23 February 1999) (24 July 1991)
Iran (Islamic Republic of) Oman
(7 December 1992) (15 March 1991)
Iraq Pakistan
(22 July 1998) (25 October 1991)
48   INCB REPORT ON PRECURSORS 2019

Non-party to the
Region Party to the 1988 Convention
1988 Convention
Philippines Thailand
(7 June 1996) (3 May 2002)

Qatar Timor-Leste
(4 May 1990) (3 June 2014)
Republic of Korea Turkey
(28 December 1998) (2 April 1996)
Saudi Arabia Turkmenistan
(9 January 1992) (21 February 1996)
Singapore United Arab Emirates
(23 October 1997) (12 April 1990)

Sri Lanka Uzbekistan

(6 June 1991) (24 August 1995)
State of Palestine Viet Nam
(29 December 2017) (4 November 1997)
Syrian Arab Republic Yemen
(3 September 1991) (25 March 1996)
Tajikistan
(6 May 1996)

Regional total
47 0
47

EUROPE Albania Franceb

(27 July 2001) (31 December 1990)
Andorra Germanyb
(23 July 1999) (30 November 1993)
Austriab Greeceb
(11 July 1997) (28 January 1992)
Belarus Holy See
(15 October 1990) (25 January 2012)
Belgiumb Hungaryb
(25 October 1995) (15 November 1996)
Bosnia and Herzegovina Iceland
(1 September 1993) (2 September 1997)
Bulgariab Irelandb
(24 September 1992) (3 September 1996)
Croatiab Italyb
(26 July 1993) (31 December 1990)
Cyprusb Latviab
(25 May 1990) (25 February 1994)
Czechiab,c Liechtenstein
(30 December 1993) (9 March 2007)
Denmarkb Lithuaniab
(19 December 1991) (8 June 1998)
Estoniab Luxembourgb
(12 July 2000) (29 April 1992)
Finlandb Maltab
(15 February 1994) (28 February 1996)
 Annex I  49

Non-party to the
Region Party to the 1988 Convention
1988 Convention
Monaco San Marino
(23 April 1991) (10 October 2000)
Montenegro Serbia
(3 June 2006) (3 January 1991)

Netherlandsb Slovakiab
(8 September 1993) (28 May 1993)
North Macedoniad Sloveniab
(13 October 1993) (6 July 1992)
Norway Spainb
(14 November 1994) (13 August 1990)
Polandb Swedenb
(26 May 1994) (22 July 1991)
Portugalb Switzerland
(3 December 1991) (14 September 2005)
Republic of Moldova United Kingdom of Great
(15 February 1995) Britain and Northern Irelandb
(28 June 1991)
Romaniab Ukraine
(21 January 1993) (28 August 1991)
Russian Federation European Unione
(17 December 1990) (31 December 1990)

Regional total
46 0
46

OCEANIA Australia New Zealand Kiribati

(16 November 1992) (16 December 1998)
Cook Islands Niue Papua New Guinea
(22 February 2005) (16 July 2012)
Fiji Palau Solomon Islands
(25 March 1993) (14 August 2019)
Marshall Islands Samoa Tuvalu
(5 November 2010) (19 August 2005)
Micronesia Tonga
(Federated States of) (29 April 1996)
(6 July 2004)
Nauru Vanuatu
(12 July 2012) (26 January 2006)

Regional total
12 4
16

World total
191 7
198

a
Since 19 April 2018, “Eswatini” has replaced “Swaziland” as the short name used in the United Nations.
b
State member of the European Union.
c
Since 17 May 2016, “Czechia” has replaced “Czech Republic” as the short name used in the United Nations.
d
Since 14 February 2019, “North Macedonia” has replaced “the former Yugoslav Republic of Macedonia” as the short name used in the United Nations.
e
Extent of competence: article 12.
50   INCB REPORT ON PRECURSORS 2019

Annex II

Submission of information by Governments pursuant

to article 12 of the United Nations Convention against
Illicit Traffic in Narcotic Drugs and Psychotropic
Substances of 1988 (form D) for the period 2014–2018
Notes:
The names of non-metropolitan territories and special administrative regions are in italics.
A blank signifies that form D was not received.
“X” signifies that a completed form D (or equivalent report) was submitted (including forms in which all
fields contained “nil”, “0”, “none”, etc.).
Entries for parties to the 1988 Convention (and for the years that they have been parties) are shaded.

Country or territory 2014 2015 2016 2017 2018

Afghanistan X X X X X
Albania X X X X X
Algeria X X X X X
Andorra X X X X
Angola X X X
Anguilla a

Antigua and Barbuda

Argentina X X X X X
Armenia X X X X X
Aruba a

Ascension Island
Australia X X X X
Austria b
X X X X X
Azerbaijan X X X X X
Bahamas
Bahrain X X X X X
Bangladesh X X X
Barbados
Belarus X X X X X
Belgium b
X X X X X
Belize X
Benin X X X X X
Bermuda a

Bhutan X X X X X
Bolivia (Plurinational State of) X X X X X
Bosnia and Herzegovina X X X X X
Botswana X
Brazil X X X X X
 Annex II  51

Country or territory 2014 2015 2016 2017 2018

British Virgin Islandsa

Brunei Darussalam X X X X X
Bulgariab X X X X X
Burkina Faso
Burundi X
Cabo Verde X X X X X
Cambodia X
Cameroon X
Canada X X X X X
Cayman Islandsa X
Central African Republic
Chad X
Chile X X X X X
China X X X X
China, Hong Kong SAR X X
China, Macao SAR X X X
Christmas Island a,c
X X
Cocos (Keeling) Islands a,c
X X
Colombia X X X X X
Comoros
Congo
Cook Islands
Costa Rica X X X X X
Côte d’Ivoire X X
Croatia b
X X X X X
Cuba
Curaçao X X X X
Cyprus b
X X X X X
Czechia b,d
X X X X X
Democratic People’s Republic of Korea X X X X
Democratic Republic of the Congo X X X X X
Denmark b
X X X X X
Djibouti
Dominica X X
Dominican Republic X X X X
Ecuador X X X X X
Egypt X X X X X
El Salvador X X X X X
Equatorial Guinea
Eritrea
Estoniab X X X X X
Eswatini e

Ethiopia X
Falkland Islands (Malvinas) X X X
52   INCB REPORT ON PRECURSORS 2019

Country or territory 2014 2015 2016 2017 2018

Fiji X
Finland b
X X X X X
Franceb X X X X X
French Polynesia a
X
Gabon X
Gambia X
Georgia X X X X X
Germany b
X X X X X
Ghana X X X X
Gibraltar
Greeceb X X X X X
Grenada
Guatemala X X X X X
Guinea
Guinea-Bissau
Guyana X X X X
Haiti X X X
Holy See f

Honduras X X X X
Hungaryb X X X X X
Iceland X X X X
India X X X X X
Indonesia X X X X X
Iran (Islamic Republic of) X X X X X
Iraq X
Irelandb X X X X X
Israel X X X X X
Italy b
X X X X X
Jamaica X X X X X
Japan X X X X X
Jordan X X X X X
Kazakhstan X X X X
Kenya X X X
Kiribati
Kuwait X
Kyrgyzstan X X X X
Lao People’s Democratic Republic X X X X X
Latvia b
X X X X X
Lebanon X X X X X
Lesotho
Liberia
Libya
Liechtensteing
Lithuaniab X X X X X
 Annex II  53

Country or territory 2014 2015 2016 2017 2018

Luxembourgb X X X X
Madagascar X X X X
Malawi
Malaysia X X X X X
Maldives X
Mali X X
Maltab X X X X X
Marshall Islands
Mauritania X
Mauritius X
Mexico X X X X X
Micronesia (Federated States of)
Monaco X X X
Mongolia X X X
Montenegro X X X X X
Montserrata X X X X X
Morocco X X X X X
Mozambique X X X
Myanmar X X X X X
Namibia X X
Nauru
Nepal X X
Netherlandsb X X X X X
New Caledonia a
X X X
New Zealand X X X X
Nicaragua X X X X X
Niger
Nigeria X X X X
Niue
Norfolk Islandc X X
North Macedonia h
X
Norway X X X X
Oman X X X X
Pakistan X X X X X
Palau
Panama X X X X X
Papua New Guinea
Paraguay X X
Peru X X X X
Philippines X X X X X
Poland b
X X X X
Portugal b
X X X X X
Qatar X X
Republic of Korea X X X X X
54   INCB REPORT ON PRECURSORS 2019

Country or territory 2014 2015 2016 2017 2018

Republic of Moldova X X X X X
Romania b
X X X X X
Russian Federation X X X X X
Rwanda X
Saint Helena
Saint Kitts and Nevis
Saint Lucia X X X X X
Saint Vincent and the Grenadines X X X X
Samoa
San Marinof X
Sao Tome and Principe
Saudi Arabia X X X X X
Senegal X X X X
Serbia X X X
Seychelles X
Sierra Leone X
Singapore X X X X
Sint Maarten
Slovakiab X X X X X
Sloveniab X X X X X
Solomon Islands
Somalia
South Africa X X X X
South Sudan X X
Spain b
X X X X X
Sri Lanka X X X X X
Sudan X X X X X
Suriname X
Sweden b
X X X X X
Switzerland X X X X X
Syrian Arab Republic X X X X X
Tajikistan X X X X
Thailand X X X X X
Timor-Leste
Togo
Tonga
Trinidad and Tobago X X X X X
Tristan da Cunha
Tunisia X X X X X
Turkey X X X X X
Turkmenistan X X X
Turks and Caicos Islands a

Tuvalu
Uganda X X X
 Annex II  55

Country or territory 2014 2015 2016 2017 2018

Ukraine X X X X
United Arab Emirates X X X X X
United Kingdom of Great Britain and Northern X X X X X
Irelandb
United Republic of Tanzania X X X X X
United States of America X X X X X
Uruguay X X X X X
Uzbekistan X X X X X
Vanuatu
Venezuela (Bolivarian Republic of) X X X X X
Viet Nam X X X X
Wallis and Futuna Islands a

Yemen X
Zambia X
Zimbabwe X X X X

Total number of Governments that submitted 127 137 134 122 126
form D

Total number of Governments requested to 213 213 213 213 213

provide information

a
Territorial application of the 1988 Convention has been confirmed by the authorities concerned.
b
State member of the European Union.
c
Information was provided by Australia.
d
Since 17 May 2016, “Czechia” has replaced “Czech Republic” as the short name used in the United Nations.
e
Since 19 April 2018, “Eswatini” has replaced “Swaziland” as the short name used in the United Nations.
f
The Holy See and San Marino did not furnish form D separately as their data are included in the report of Italy.
g
Liechtenstein did not furnish form D separately as its data are included in the report of Switzerland.
h
Since 14 February 2019, “North Macedonia” has replaced “the former Yugoslav Republic of Macedonia” as the short name used in the United Nations.
56   INCB REPORT ON PRECURSORS 2019

Annex III

Seizures of substances in Tables I and II of the United

Nations Convention against Illicit Traffic in Narcotic
Drugs and Psychotropic Substances of 1988, as
reported to the International Narcotics Control Board,
2014–2018
1. Tables A and B below show information on seizures of the substances included in Tables I and II of the United
Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances of 1988, furnished to the
International Narcotics Control Board by Governments in accordance with article 12, paragraph 12, of the Convention.
2. The tables include data on domestic seizures and on seizures effected at points of entry or exit. They do not include
reported seizures of substances where it is known that the substances were not intended for the illicit manufacture of
drugs (for example, seizures effected on administrative grounds or seizures of ephedrine/pseudoephedrine preparations
to be used as stimulants). Stopped shipments are also not included. The information may include data submitted by
Governments through means other than form D; in such cases, the sources are duly noted.

Units of measure and conversion factors

3. Units of measure are indicated for every substance. As fractions of full units are not listed in the tables, figures are
rounded as necessary.
4. For a variety of reasons, individual quantities of some substances seized are reported to the Board using different
units; for instance, one country may report seizures of acetic anhydride in litres, another in kilograms.
5. To enable a proper comparison of collected information, it is important that all data be collated in a standard format.
To simplify the necessary standardization process, figures are given in grams or kilograms where the substance is a solid
and in litres where the substance (or its most common form) is a liquid.
6. Seizures of solids reported to the Board in litres have not been converted into kilograms and are not included in the
tables, as the actual quantity of substance in solution is not known.
7. For seizures of liquids, quantities reported in kilograms have been converted into litres using the following factors:

Conversion factor
Substance
(kilograms to litres)a
Acetic anhydride 0.926
Acetone 1.269
Ethyl ether 1.408
Hydrochloric acid (39.1% solution) 0.833
Isosafrole 0.892
3,4-Methylenedioxyphenyl-2-propanone 0.833
Methyl ethyl ketone 1.242
1-Phenyl-2-propanone 0.985
Piperidine 1.160
Safrole 0.912
Sulphuric acid (concentrated solution) 0.543
Toluene 1.155
a
Derived from density; see Merck, The Merck Index (Rahway, New Jersey, Merck, 1989).
 Annex III  57

8. As an example, to convert 1,000 kilograms of methyl ethyl ketone into litres, multiply by 1.242, i.e. 1,000 × 1.242 =
1,242 litres.

9. For the conversion of gallons to litres, it has been assumed that in Colombia the United States gallon is used, with
3.785 litres to the gallon, and in Myanmar the imperial gallon is used, with 4.546 litres to the gallon.

10. If reported quantities have been converted, the converted figures are listed in the tables in italics.

11. The names of territories appear in italics.

12. A dash (–) signifies that the report did not include data on seizures of the particular substance in the reporting year.

13. A slashed degree symbol (ø) signifies less than the smallest unit of measurement shown for that substance (for
example, less than 1 kilogram).

14. Discrepancies may exist between the regional total seizure figures and the world total figures because the actual
quantities seized were rounded to whole numbers.
Table A. Seizures of substances in Table I of the 1988 Convention as reported to the International Narcotics Control Board, 2014–2018

Country or territory Year

(kilograms)
(kilograms)
(kilograms)
(kilograms)b
Safrole (litres)

Isosafrole (litres)
propanone (litres)

(ANPP)a (kilograms)
Ergotamine (grams)

Ergometrine (grams)
Lysergic acid (grams)
Piperonal (kilograms)

Ephedrine (kilograms)

Acetic anhydride (litres)

3,4-Methylenedioxyphenyl-2-
Phenylacetic acid (kilograms)
Pseudoephedrine (kilograms)

1-Phenyl-2-propanone (litres)
58   INCB REPORT ON PRECURSORS 2019

Pseudoephedrine preparations

4-Anilino-N-phenethylpiperidine
N-Phenethyl-4-piperidone (NPP)a

N-Acetylanthranilic acid (kilograms)

Ephedrine preparationsb (kilograms)
Norephedrine (Phenylpropanolamine)
Potassium permanganate (kilograms)

alpha-Phenylacetoacetonitrile (APAAN)c

AFRICA
Benin 2016 - - - - 295 - - - - - - - - - - - - - - -
2017 - - - - 152 - - - - - - - - - - - - - - -
2018 - - - - - - - - - - - - - - - - - - ø -
Kenya 2015 - - - 18 - - - - - - - - - - - - - - - -
Mali 2015 - - - 12 - - - - - - - - - - - - - - - -
Mozambique 2018 - 83 - 63 - - - - - - - - - - - - - - - -
Namibia 2014 - - - 21 - - - 2 100 - - - - - - - - - - - -
2016 - - - - - - - - - - - - - - - - - - - 2 100
Nigeria 2015 - - - 785 - - - - - - - - - - - - - - - -
2016 - - - 444 - - - - - - - - - - - - - - - -
2018 - - - 326 - - - - - - - - - - - - - - - -
South Africa 2018 - - - 15 - - - - - - - - - - - - - - - -
United Republic of Tanzania 2014 - - - 4 - - - - - - - - - - - - - - - -
2017 15 - - - - - - - - - - - ø - - - - - - -
Zambia 2014 - - - - - ø - - - - - - - - - - - - - -
Zimbabwe 2014 - - - 70 - - - - - - - - - - - - - - - -
Regional total 2014 0 0 0 95 0 0 0 2 100 0 0 0 0 0 0 0 0 0 0 0 0
2015 0 0 0 816 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
2016 0 0 0 444 295 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2 100
2017 15 0 0 0 152 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
2018 0 83 0 404 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
Country or territory Year

(kilograms)
(kilograms)
(kilograms)
(kilograms)b
Safrole (litres)

Isosafrole (litres)
propanone (litres)

(ANPP)a (kilograms)
Ergotamine (grams)

Ergometrine (grams)
Lysergic acid (grams)
Piperonal (kilograms)

Ephedrine (kilograms)

Acetic anhydride (litres)

3,4-Methylenedioxyphenyl-2-
Phenylacetic acid (kilograms)
Pseudoephedrine (kilograms)

1-Phenyl-2-propanone (litres)
Pseudoephedrine preparations

4-Anilino-N-phenethylpiperidine
N-Phenethyl-4-piperidone (NPP)a

N-Acetylanthranilic acid (kilograms)

Ephedrine preparationsb (kilograms)
Norephedrine (Phenylpropanolamine)
Potassium permanganate (kilograms)

alpha-Phenylacetoacetonitrile (APAAN)c
AMERICAS
CENTRAL AMERICA AND THE CARIBBEAN
Honduras 2016 - - - - - - - - - - - - - - - - - - -
2018 - - - - - 150 - - - - - - - - - - - - -
Regional total 2014 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
2015 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
2016 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
2017 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
2018 0 0 0 0 0 0 150 0 0 0 0 0 0 0 0 0 0 0 0 0

NORTH AMERICA
Canada 2014 ø - - 65 - - - - 14 - - - - - - - ø ø - 2
2015 ø - - ø ø - ø - ø ø - - - - ø - - - ø ø
2016 - - - 639 ø - - - - - - - - - - - 5 - -
Mexico 2014 13 368 - - - - - - - - - - - 1 315 - 5 892 - - - - -
2015 3 356 - - - - - - - - - - - 550 - 16 537 - - - - -
2016 2 900 - - - - - - - - - - - 59 - 7 033 - - - - -
2017 8 601 - - - - - - - - - - - 19 435 - 2 455 - - - - -
2018 133 - ø - - - - - - - - 1 342 - 19 015 - - - - -
United States of America 2014 ø - - ø ø - - - - - - - - - ø - - 19 1 -
2015 - - - ø - - - - - - - - - - - - - 210 - -
2016 ø - 52 27 - - - 1 3 880 ø ø ø - 1 288 ø 127 - 3
2017 - - - 6 - - - - - - 1 50 4 - - - - 195 - 32
2018 - - 275 2 - - - - 594 - 7 ø - ø - - 28 - ø
Annex III  59
Country or territory Year

(kilograms)
(kilograms)
(kilograms)
(kilograms)b
Safrole (litres)

Isosafrole (litres)
propanone (litres)

(ANPP)a (kilograms)
Ergotamine (grams)

Ergometrine (grams)
Lysergic acid (grams)
Piperonal (kilograms)

Ephedrine (kilograms)

Acetic anhydride (litres)

3,4-Methylenedioxyphenyl-2-
Phenylacetic acid (kilograms)
Pseudoephedrine (kilograms)

1-Phenyl-2-propanone (litres)
Pseudoephedrine preparations

4-Anilino-N-phenethylpiperidine
N-Phenethyl-4-piperidone (NPP)a

N-Acetylanthranilic acid (kilograms)

Ephedrine preparationsb (kilograms)
Norephedrine (Phenylpropanolamine)
Potassium permanganate (kilograms)

alpha-Phenylacetoacetonitrile (APAAN)c
60   INCB REPORT ON PRECURSORS 2019

Regional total 2014 13 368 0 0 65 0 0 0 0 14 0 0 0 1 315 0 5 893 0 1 19 1 2

2015 3 356 0 0 1 0 0 0 0 0 0 0 0 550 0 16 537 0 0 210 0 0
2016 2 900 0 52 665 0 0 0 1 3 880 0 0 0 59 0 7 034 288 1 132 0 3
2017 8 601 0 0 6 0 0 0 0 0 0 1 50 19 439 0 2 455 0 0 195 0 32
2018 133 0 275 2 0 0 0 0 594 0 7 0 1 342 0 19 015 0 0 28 0 0

SOUTH AMERICA
Argentina 2014 33 - - 24 - - - - - - - - - - - - - - - -
2015 1 044 - - 47 - - - - - - - - - - - - 56 - - -
2016 - - - 250 - - - - - - - - - - - - ø - - -
2017 276 - - - - - - - - 15 - - - - - - 2 650 - - -
2018 5 - - 168 - - - - - - - - - - - - 7 - - -
Bolivia (Plurinational State of) 2014 - - - - - - - - - - - - - - - - 1 492 - - -
2015 - - - - - - - - - - - - - - - - 862 - - -
2016 - - - - - - - - - - - - - - - - 2 001 - - -
2017 - - - - - - - - - - - - - - - - 2 401 - - -
2018 - - - - - - - - - - - - - - - - 2 642 - - -
Brazil 2014 - - - - - - - - - - - - - - - - 1 - - -
2016 - - - ø - - - - - 1 - - - - - - 8 - - -
2017 - - - - - - - - - - - - - - - - 10 - - -
Chile 2015 - - - - ø - - - - - - - - - - - - - - -
2016 - - - ø - - - - - - - - - - - - - - - -
2017 - - - ø - - - - - - - - - - - - - - - -
2018 - - - - - - 3 - - - - - - - - - 2 506 - ø -
Country or territory Year

(kilograms)
(kilograms)
(kilograms)
(kilograms)b
Safrole (litres)

Isosafrole (litres)
propanone (litres)

(ANPP)a (kilograms)
Ergotamine (grams)

Ergometrine (grams)
Lysergic acid (grams)
Piperonal (kilograms)

Ephedrine (kilograms)

Acetic anhydride (litres)

3,4-Methylenedioxyphenyl-2-
Phenylacetic acid (kilograms)
Pseudoephedrine (kilograms)

1-Phenyl-2-propanone (litres)
Pseudoephedrine preparations

4-Anilino-N-phenethylpiperidine
N-Phenethyl-4-piperidone (NPP)a

N-Acetylanthranilic acid (kilograms)

Ephedrine preparationsb (kilograms)
Norephedrine (Phenylpropanolamine)
Potassium permanganate (kilograms)

alpha-Phenylacetoacetonitrile (APAAN)c
Colombia 2014 - - - - - - - - - - - - - - - - 166 291 - - -
2015 8 - - - - - - - - - - - - - - - 57 639 - - -
2016 12 - - - - - - - - - - - - - - - 582 540 - - -
2017 95 - - - - - - - - - - - - - - - 97 889 - - -
2018 38 - - - - - - - - - - - - - - - 70 444 - - -
Ecuador 2014 - - - - - - - - - - - - - - - - 10 - - -
2015 - - - - - - - - - - - - - - - - 2 - - -
2016 - - - - - - - - - - - - - - - - 5 - - -
2017 - - - - - - - - - - - - - - - - 25 - - -
2018 - - - - - - - - - - - - - - - - 2 - - -
Peru 2014 15 - - - - - - - - - - - - - - - 2 735 - - -
2015 - - - - - - - - - - - - - - - - 53 - - -
2016 2 889 - - - - - - - - - - - - - - - 248 - - -
2018 - - - - - - - - - - - - - - - - 52 - - -
Venezuela (Bolivarian Republic of) 2014 - - - - - - - - - - - - - - - - 1 120 - - -
2015 - - - - - - - - - - - - - - - - 1 554 - - -
2016 - - - - - - - - - - - - - - - - 200 - - -
2017 - - - - - - - - - - - - - - - - 660 - - -
2018 5 - - - - - 15 - - - - - - - - - 1 330 - - -

Regional total 2014 48 0 0 24 0 0 0 0 0 0 0 0 0 0 0 0 171 649 0 0 0

2015 1 052 0 0 47 0 0 0 0 0 0 0 0 0 0 0 0 60 166 0 0 0
2016 2 901 0 0 250 0 0 0 0 0 1 0 0 0 0 0 0 585 003 0 0 0
2017 370 0 0 0 0 0 0 0 0 15 0 0 0 0 0 0 103 635 0 0 0
2018 48 0 0 168 0 0 18 0 0 0 0 0 0 0 0 0 76 983 0 0 0
Annex III  61
Country or territory Year

(kilograms)
(kilograms)
(kilograms)
(kilograms)b
Safrole (litres)

Isosafrole (litres)
propanone (litres)

(ANPP)a (kilograms)
Ergotamine (grams)

Ergometrine (grams)
Lysergic acid (grams)
Piperonal (kilograms)

Ephedrine (kilograms)

Acetic anhydride (litres)

3,4-Methylenedioxyphenyl-2-
Phenylacetic acid (kilograms)
Pseudoephedrine (kilograms)

1-Phenyl-2-propanone (litres)
Pseudoephedrine preparations

4-Anilino-N-phenethylpiperidine
N-Phenethyl-4-piperidone (NPP)a

N-Acetylanthranilic acid (kilograms)

Ephedrine preparationsb (kilograms)
Norephedrine (Phenylpropanolamine)
Potassium permanganate (kilograms)

alpha-Phenylacetoacetonitrile (APAAN)c
62   INCB REPORT ON PRECURSORS 2019

ASIA
EAST AND SOUTH-EAST ASIA
Chinad 2014 22 635 - - 31 576 3 222 - - - - 33 ø - 49 651 - 3 241 - 2 120 - - -
2015 11 070 ø 23 480 221 - - - - ø 6 - 3 - 5 407 - 31 550 13 - -
2016 56 177 - - 1 409 3 367 - - - - 376 - - - - 11 639 - 45 - - ø
2018 53 500 150 - 19 370 5 718 449 - - - 18 - - 6 552 - 3 873 - 3 521 908 - -
b
China, Hong Kong SAR 2016 - - - 43 - - - - - - - - - - - ø - - -
b
2018 - - - 11 - - - - - - - - - - - - ø ø -
China, Macao SAR 2014 - - - - ø - - - - - - - - - - - - - - -
2015 - - - - ø - - - - - - - - - - - - - - -
Indonesia 2014 - - - ø ø - - - - - - - - - - - - - - -
2015 - - - - ø - - - - - - - - - - - - - ø -
2016 - - - - 102 - - - - - - - - - - - - - - -
2017 - - - - ø - - - - - - - - - - ø - - - -
Japan 2014 - - - 5 - - - - - - - - - - - - - - - -
2015 - - - - - - - - - - - - - - - - - 6 - -
2016 - - - - - - - - - - - - ø - - - - ø - -
2017 7 647 - - 1 - - - - - - - - - - - 1 - - - -
2018 - - - 5 - - - - - - - - - - - - - - - -
Malaysia 2014 - - - - 33 - - - - - - - - - - - 1 287 112 -
2015 - - - 75 - - - - - - - - - - - - - 56 - -
2016 - - - 60 - - - - - - - - - - - - - - - -
2017 - - - 262 - - - - - - - - - - - - - 14 - -
2018 - - - 197 - - - - - - - - - - - - - - - -
Myanmar 2014 - - - - - - - - - - - - - - 4 800 - - - - -
2015 60 - - ø - - - - - - - - - - - - - - - -
2016 16 - - 534 - - - - - - - - - - - - - 181 - -
2017 1 318 - - - - - - - - - - - - - - - - 421 - -
b
2018 40 1 000 - - 140 - - - - - - - 4 000 - 3 298 - - - -
Country or territory Year

(kilograms)
(kilograms)
(kilograms)
(kilograms)b
Safrole (litres)

Isosafrole (litres)
propanone (litres)

(ANPP)a (kilograms)
Ergotamine (grams)

Ergometrine (grams)
Lysergic acid (grams)
Piperonal (kilograms)

Ephedrine (kilograms)

Acetic anhydride (litres)

3,4-Methylenedioxyphenyl-2-
Phenylacetic acid (kilograms)
Pseudoephedrine (kilograms)

1-Phenyl-2-propanone (litres)
Pseudoephedrine preparations

4-Anilino-N-phenethylpiperidine
N-Phenethyl-4-piperidone (NPP)a

N-Acetylanthranilic acid (kilograms)

Ephedrine preparationsb (kilograms)
Norephedrine (Phenylpropanolamine)
Potassium permanganate (kilograms)

alpha-Phenylacetoacetonitrile (APAAN)c
Philippines 2014 - - - 510 - - - - - - ø - - - - ø - - - -
2015 - - - 50 - - - - - - ø - - - - - - 2 - -
2016 - - - 10 - - - - - - - - - - - - - - - -
2017 - - - ø - - - - - - - - - - - - - 209 - -
2018 - - - 11 212 - - - - - - - - - - - - - - - -
Thailand 2014 - - - - - - - - - - - - - - - - - - 6 -
2015 - - - - - - - - - - - - - - - - - - 3 -
2016 - - - - ø - - - - - - - - - - - - - 3 829 -
2017 - - - - - - - - - - - - - - - - - - 1 153 -
Viet Nam 2014 - - - 4 - - - - - - - - - - - - - 22 - -

Regional total 2014 22 635 0 0 32 095 3 255 0 0 0 0 33 0 0 49 651 0 8 041 0 2 121 309 118 0
2015 11 130 0 0 23 604 221 0 0 0 0 0 6 0 3 0 5 407 0 31 550 77 3 0
2016 56 193 0 0 2 056 3 470 0 0 0 0 376 0 0 0 0 11 639 0 45 181 3 829 0
2017 8 965 0 0 264 0 0 0 0 0 0 0 0 0 0 0 1 0 644 1 153 0
2018 53 540 1 150 0 30 795 5 858 449 0 0 0 18 0 0 10 552 0 7 171 0 3 522 908 18 0

SOUTH ASIA
India 2014 100 - - 654 - - - - - - - - - - 78 - - - 676 -
2015 4 - - 97 ø - - - 472 43 - - - - - - - 730 ø -
2016 2 464 - - - 21 179 - - - 13 - - - - - - - - - 155 -
2017 23 - - - 1 120 - - - 349 - - - - - - - - - 1 869 -
2018 9 716 - - - 101 - - - ø - - - - - - - - - - -

Regional total 2014 100 0 0 654 0 0 0 0 0 0 0 0 0 0 78 0 0 0 676 0

2015 4 0 0 97 0 0 0 0 472 43 0 0 0 0 0 0 0 730 0 0
2016 2 464 0 0 0 21 179 0 0 0 13 0 0 0 0 0 0 0 0 0 155 0
2017 23 0 0 0 1 120 0 0 0 349 0 0 0 0 0 0 0 0 0 1 869 0
Annex III  63

2018 9 716 0 0 0 101 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Country or territory Year

(kilograms)
(kilograms)
(kilograms)
(kilograms)b
Safrole (litres)

Isosafrole (litres)
propanone (litres)

(ANPP)a (kilograms)
Ergotamine (grams)

Ergometrine (grams)
Lysergic acid (grams)
Piperonal (kilograms)

Ephedrine (kilograms)

Acetic anhydride (litres)

3,4-Methylenedioxyphenyl-2-
Phenylacetic acid (kilograms)
Pseudoephedrine (kilograms)

1-Phenyl-2-propanone (litres)
Pseudoephedrine preparations

4-Anilino-N-phenethylpiperidine
N-Phenethyl-4-piperidone (NPP)a

N-Acetylanthranilic acid (kilograms)

Ephedrine preparationsb (kilograms)
Norephedrine (Phenylpropanolamine)
Potassium permanganate (kilograms)

alpha-Phenylacetoacetonitrile (APAAN)c
64   INCB REPORT ON PRECURSORS 2019

WEST ASIA
Afghanistan 2014 7 751 - - - - - - - - - - - - - - - - - - -
2015 3 761 - - - - - - - - - - - - - - - - - - -
2016 10 439 - - - - - - - - - - - - - - - - 16 - -
2017 37 715 - - - - - - - - - - - - - - - - - - -
2018 7 364 - - - - - - - - - - - - - - - - 51 - -
Armenia 2014 ø - - - - - - - - - - - - - - - - - - -
2015 ø - - - - - - - - - - - - - - - - - - -
2016 ø - - - - - - - - - - - - - - - - - - -
2017 ø - - - - - - - - - - - - - - - ø - - -
2018 ø - - - - - - - - - - - - - - - - - - -
Georgia 2016 - - - ø - - - - - - - - - - - - - - ø -
2017 - - - ø - - - - 3 - - - - - - - - - - -
2018 13 733 - - - - - - - - - - - - - - - - ø - -
Iran (Islamic Republic of) 2016 18 520 - - - - - - - - - - - - - - - - - - -
2017 20 294 - - - - - - - - - - - - - - - - - - -
2018 27 680 - - - - - - - - - - - - - - - - - - -
Jordan 2016 - - - - - - - - - - - - - - 3 260 - - - - -
2018 - - - - - - - - - - - - - 11 048 926 - - - - -
Kazakhstan 2015 - - - - - - - - - - - - - - - - 13 401 - - -
b b
Lebanon 2014 - - - - - - - - - - - - - - - - - -
2015 - - - - - - - - - - - - 16 082 - - - - - - -
2018 2 - - - - - - - - - - - - - - - - - - -
Pakistan 2014 185 - - 35 - - - - - - - - - - - - - - - -
2015 5 319 - - - - - - - - - - - - - - - - - - -
2016 40 000 - - - - - - - - - - - - - - - - - - -
2017 6 918 - - - - - - - - - - - - - - - - - - -
2018 19 803 - - - - - - - - - - - - - - - - - - -
Country or territory Year

(kilograms)
(kilograms)
(kilograms)
(kilograms)b
Safrole (litres)

Isosafrole (litres)
propanone (litres)

(ANPP)a (kilograms)
Ergotamine (grams)

Ergometrine (grams)
Lysergic acid (grams)
Piperonal (kilograms)

Ephedrine (kilograms)

Acetic anhydride (litres)

3,4-Methylenedioxyphenyl-2-
Phenylacetic acid (kilograms)
Pseudoephedrine (kilograms)

1-Phenyl-2-propanone (litres)
Pseudoephedrine preparations

4-Anilino-N-phenethylpiperidine
N-Phenethyl-4-piperidone (NPP)a

N-Acetylanthranilic acid (kilograms)

Ephedrine preparationsb (kilograms)
Norephedrine (Phenylpropanolamine)
Potassium permanganate (kilograms)

alpha-Phenylacetoacetonitrile (APAAN)c
Tajikistan 2018 266 - - - - - - - - - - - - - - - - - - -
Turkey 2014 854 - - 33 - - - - - - - - - - - - - - - -
2015 4 402 - - - - - - - - - - - - - - - - - - -
2016 1 588 - - - - - - - - - - - - - - - - - - -
2017 23 238 - - - - - - - - - - - - - - - - - - -
2018 38 569 - - - - - - - - - - - - - - - - - - -
United Arab Emirates 2018 - - - - - - - - - - - - - - - - ø - - -
Uzbekistan 2014 - - - - - - - - - - - - - - - - 52 - - -
2015 - - - - - - - - - - - - - - - - 32 684 - - -
2016 - - - - - - - - - - - - - - - - 2 - - -
2017 20 - - - - - - - - - - - - - - - 4 - - -
2018 - - - - - - - - - - - - - - - - 822 - - -

Regional total 2014 8 790 0 - 68 0 0 0 0 0 0 0 0 0 0 0 0 52 0 0 0

2015 13 481 0 - 0 0 0 0 0 0 0 0 0 16 082 0 0 0 46 085 0 0 0
2016 70 547 0 - 0 0 0 0 0 0 0 0 0 0 0 3 260 0 2 16 0 0
2017 88 184 0 - 0 0 0 0 0 3 0 0 0 0 0 0 0 4 0 0 0
2018 107 416 0 - 0 0 0 0 0 0 0 0 0 0 11 048 926 0 822 51 0 0

EUROPE
STATES NOT MEMBERS OF THE EUROPEAN UNION
Bosnia and Herzegovina 2018 1 - ø - - - - - - - - - - - - 1 525 - 8 -
Belarus 2014 - - - - - - - - - - - - - - - - - ø - -
2015 - - - - - - - - - - - - - - - - - - ø -
2016 - - - - ø - - - - - - - - - - - - - ø -
2017 - - - - - - - - ø - - - - - - - - - - -
2018 - - - - - - - - - - - - - - - - - - - -
Annex III  65
Country or territory Year

(kilograms)
(kilograms)
(kilograms)
(kilograms)b
Safrole (litres)

Isosafrole (litres)
propanone (litres)

(ANPP)a (kilograms)
Ergotamine (grams)

Ergometrine (grams)
Lysergic acid (grams)
Piperonal (kilograms)

Ephedrine (kilograms)

Acetic anhydride (litres)

3,4-Methylenedioxyphenyl-2-
Phenylacetic acid (kilograms)
Pseudoephedrine (kilograms)

1-Phenyl-2-propanone (litres)
Pseudoephedrine preparations

4-Anilino-N-phenethylpiperidine
N-Phenethyl-4-piperidone (NPP)a

N-Acetylanthranilic acid (kilograms)

Ephedrine preparationsb (kilograms)
Norephedrine (Phenylpropanolamine)
Potassium permanganate (kilograms)

alpha-Phenylacetoacetonitrile (APAAN)c
66   INCB REPORT ON PRECURSORS 2019

Iceland 2016 - - - - - - - - - - - - - - - - - - ø -
Republic of Moldova 2014 - - - - - - - - - - - - - - - - - - ø -
2015 - - - ø - - - - - - - - - - - - ø ø ø -
2016 - - - - - - - - - - - - - - - - - - - 6
2017 - - - - - - - - - - - - - - - - - - ø -
Norway 2014 - - - - - - - - - - - - - - ø - - - - -
2015 - - - - ø - - - - - - - - - - - - - ø -
2018 - - - - - - - - - - - - - - - - 4 - - -
Russian Federation 2014 17 - - - ø - - - - - - - - - ø - - - ø -
2015 47 - - ø - - - - - - - - - - - - - - ø -
2016 6 - - 3 - - - - - - - - - - 10 - - - - -
2017 19 - - - 3 - - - - - - - - - 1 - - ø - -
2018 9 - - 2 - - - - 2 000 - - - - - 6 - - - - -
Serbia 2018 - - - - - - - - - - - - - - - - - 18 - -
Switzerland 2014 - - - - ø - - - - - - - - - - - - - - 3
2016 - - - - - - - - - - - - - - - - - - - ø
Ukraine 2015 57 - - - ø - - - - - ø - 25 - - ø 10 ø 47 -
2016 97 - - - 253 - - - - ø - - - - 430 - 14 ø 2 -
2017 310 - - 5 ø - - - - - - - - - 1 - 12 ø 6 -
2018 - - - - ø - ø - - 1 - - - 12 - ø 1 - 3

STATES MEMBERS OF THE EUROPEAN UNION

Austria 2014 - - - - - - - - - - - - - - - - ø - - -
2015 2 037 - - - - - - - - - - - - - - - - - - -
2016 - - - ø - - - - - - - - - - - - - - - -
2017 - - - - - - - - - - - - - - - - ø - - -
2018 - - - - - - - - - - - - - - - - 1 - - -
Country or territory Year

(kilograms)
(kilograms)
(kilograms)
(kilograms)b
Safrole (litres)

Isosafrole (litres)
propanone (litres)

(ANPP)a (kilograms)
Ergotamine (grams)

Ergometrine (grams)
Lysergic acid (grams)
Piperonal (kilograms)

Ephedrine (kilograms)

Acetic anhydride (litres)

3,4-Methylenedioxyphenyl-2-
Phenylacetic acid (kilograms)
Pseudoephedrine (kilograms)

1-Phenyl-2-propanone (litres)
Pseudoephedrine preparations

4-Anilino-N-phenethylpiperidine
N-Phenethyl-4-piperidone (NPP)a

N-Acetylanthranilic acid (kilograms)

Ephedrine preparationsb (kilograms)
Norephedrine (Phenylpropanolamine)
Potassium permanganate (kilograms)

alpha-Phenylacetoacetonitrile (APAAN)c
Belgium 2014 - - - 2 - - - - - 5 - - - 122 25 - - - - -
2015 - - - - - - - - - - - - - 637 435 - - - - 1
2016 - - - 3 - - - - - - - - - 4 1 - - - - -
2017 1 836 - - 4 - - - - - 236 - - - - 38 - - - - -
2018 - - - - - - - - - - - 3 - 50 1 400 - - - - -
Bulgaria 2014 - - - - - - - - - - - - - 1 980 - - - - 841 -
2015 - - - ø - - - - - - - - - - - - - 32 66 -
2016 - - - - - - - - - - - - - - - - - - ø -
2017 10 623 - - - - - - - - 4 177 - - - - - - - - - -
2018 780 - - - - - - - - - - - - 4 400 - - - - 80 -
Croatia 2014 - - - - ø - - - - - - - - - - - - - ø -
Czechiae 2014 - - - 14 2 - - - - - - - - - - - - 12 351 -
2015 - - - - - - - - - - - - - - - - - - 77 -
2016 - - - ø - - - - - - - - - - - - - 20 26 -
2017 - - - - - - - - - - - - - - - - - 3 28 -
2018 - - - 1 - - - - - - - - - - - - - ø 58 -
Denmark 2018 - - - - - - - - - - - - - - 100 - - - - -
Estonia 2014 ø - - - ø - - - - - - - 100 5 - - - - - -
2015 - - - - - - - - - - - - - - ø - - - - -
2016 - - - - - - - - - - - 10 - - - - - - - -
2017 - - - ø - - - - - - 5 - - - - ø - - -
2018 - - - - ø - - - - - - ø - - - - - - -
Finland 2014 - - - - ø - - - - - - - - - - - - - - -
2015 - - - - 2 - - - - - - - - - ø ø - - ø -
2016 - - - - - - - - - - - - - - 1 ø ø - ø -
2017 - - - - ø - - - - - - - - - ø - - - ø -
Annex III  67
Country or territory Year

(kilograms)
(kilograms)
(kilograms)
(kilograms)b
Safrole (litres)

Isosafrole (litres)
propanone (litres)

(ANPP)a (kilograms)
Ergotamine (grams)

Ergometrine (grams)
Lysergic acid (grams)
Piperonal (kilograms)

Ephedrine (kilograms)

Acetic anhydride (litres)

3,4-Methylenedioxyphenyl-2-
Phenylacetic acid (kilograms)
Pseudoephedrine (kilograms)

1-Phenyl-2-propanone (litres)
Pseudoephedrine preparations

4-Anilino-N-phenethylpiperidine
N-Phenethyl-4-piperidone (NPP)a

N-Acetylanthranilic acid (kilograms)

Ephedrine preparationsb (kilograms)
Norephedrine (Phenylpropanolamine)
Potassium permanganate (kilograms)

alpha-Phenylacetoacetonitrile (APAAN)c
68   INCB REPORT ON PRECURSORS 2019

France 2014 - - - 15 - - - - - - - - - - 1 - - - - -
2015 - - - ø - - - - - - - - - - - - - - ø -
2016 - - - 11 ø - - - 500 888 - - - - - - - - - -
2018 - - ø - - - - - - - - - - - - - - - - -
Germany 2014 - - - ø ø - - - - - - - - 5 105 2 - ø - - -
2015 1 - - 4 - - - - - - - - - 38 2 ø ø ø ø -
2016 - - - 15 - - 200 - - - - - - 200 - - - - - -
2017 - - - 9 - - - - - - - - - - - - - - - -
2018 46 - - 5 - - - - - - - - - 150 ø - - 63 2 -
Hungary 2014 - - - ø ø - - - - - - - - - - - - - - -
2015 - - - - ø - - - - - - - - - 14 - - - - -
2016 - - - - ø - - - - - - - - - - - ø - - -
2017 - - - ø 8 - - - - - - - - - - - - - - -
2018 - - - ø 125 - - - - - - - - - ø - - - 8 -
Ireland 2014 - - - - - - - - - - - - - - 22 - - - - -
2015 - - - ø - - - - - - - - - - - - - - - -
2016 - - - 5 - - - - - - - - - - - - - - - -
2017 - - - 7 ø - - - - - - - - - - - - - - -
2018 - - - 10 - - - - - - - - - - - - - - - -
Latvia 2016 - - - - - - - - - - - - - - - - - ø - -
2018 - - - - - - - - - - - - - - 8 - - - - -
Lithuania 2014 - - - - - - - - - - - - - - 690 - - - - -
2015 ø - - - - - - - - - - - - - - - - - - -
2016 - - - - - - - - - - - - - - ø - - - - -
2017 - - - - - - - - - - - - - 7 ø - - - - -
2018 - - - ø - - - - - - - - - 7 580 - - - - -
Country or territory Year

(kilograms)
(kilograms)
(kilograms)
(kilograms)b
Safrole (litres)

Isosafrole (litres)
propanone (litres)

(ANPP)a (kilograms)
Ergotamine (grams)

Ergometrine (grams)
Lysergic acid (grams)
Piperonal (kilograms)

Ephedrine (kilograms)

Acetic anhydride (litres)

3,4-Methylenedioxyphenyl-2-
Phenylacetic acid (kilograms)
Pseudoephedrine (kilograms)

1-Phenyl-2-propanone (litres)
Pseudoephedrine preparations

4-Anilino-N-phenethylpiperidine
N-Phenethyl-4-piperidone (NPP)a

N-Acetylanthranilic acid (kilograms)

Ephedrine preparationsb (kilograms)
Norephedrine (Phenylpropanolamine)
Potassium permanganate (kilograms)

alpha-Phenylacetoacetonitrile (APAAN)c
Netherlands 2014 - - - - - - - - - - - - - 3 090 428 5 - - 2 -
2015 - - - - - - - - - 507 - - 258 710 525 45 26 - - 2
2016 75 - - - - - - - - 148 - - - 393 22 1 - - - 61
2017 6 953 - - 3 - - - - - 5 397 - - - 59 981 10 - 8 - 2 970
2018 13 840 - - - - - - - - 190 - - 132 3 928 1 270 ø 23 29 - 175
Poland 2014 4 - - ø - - - - - - - - - 611 1 472 - - ø - -
2015 - - - 1 - - - - - - - - - 31 6 920 - - - 35 -
2016 - - - - 26 - - - - - - - - - 107 - - - - 2
2017 1 001 - - - - - - - - - - - - 5 000 112 - - - - -
Portugal 2015 - - - ø - - - - - - - - - - - - - - - -
2016 - - - - ø - - - - - - - - - - - - - ø -
2017 - - - ø - - - - - - - - - - - - - - - -
2018 - - - - - - - - - - - - - - 5 786 - - ø ø -
Romania 2014 - - - - - - - - - - - - - 150 - - - - - -
2018 - - - ø - - - - - - - - - - 44 - - - - -
Slovakia 2014 - - - ø - - - - - - - - - - - - ø - 11 -
2015 - - - ø - - - - - - - - - - - - 1 000 ø - -
2016 - - - ø - - - - - - - - - - - - - - ø -
2017 - - - ø - - - - - - - - - - - - - 2 - -
Slovenia 2018 2 778 - - - - - - - - - - - - - - - - - - -
Spain 2014 110 - - - - - - - - - - - - - - - - - - -
2015 1 - - 2 - - - - - - - - 2 122 - - - - - -
2016 - - - - 3 - - - - - - - - - - - 8 - - -
2017 - - - ø - - - - - - ø - - - - 27 5 - - -
2018 - - - 23 - - - - - 527 - - - - - 29 45 - - -
Sweden 2014 - - - - 3 - - - - - - - - - - - - - - -
2015 - - - - 1 - - - - - - - - - - - - - - -
a
Annex III  69

2016 - - - - - - - - - - - - - 7 - - - ø -
Country or territory Year

(kilograms)
(kilograms)
(kilograms)
(kilograms)b
Safrole (litres)

Isosafrole (litres)
propanone (litres)

(ANPP)a (kilograms)
Ergotamine (grams)

Ergometrine (grams)
Lysergic acid (grams)
Piperonal (kilograms)

Ephedrine (kilograms)

Acetic anhydride (litres)

3,4-Methylenedioxyphenyl-2-
Phenylacetic acid (kilograms)
Pseudoephedrine (kilograms)

1-Phenyl-2-propanone (litres)
Pseudoephedrine preparations

4-Anilino-N-phenethylpiperidine
N-Phenethyl-4-piperidone (NPP)a

N-Acetylanthranilic acid (kilograms)

Ephedrine preparationsb (kilograms)
Norephedrine (Phenylpropanolamine)
Potassium permanganate (kilograms)

alpha-Phenylacetoacetonitrile (APAAN)c
70   INCB REPORT ON PRECURSORS 2019

Sweden (continued) 2017 - - - - ø - - - - - - - - - - ø - - ø -

2018 - - - - ø - - - - - - - - - - - - - - -
United Kingdom of Great
Britain and Northern Ireland 2016 - - - 29 ø - - - - 20 - - - - - - - - - -
2017 - - - - - - - - - 9 21 - - - 594 - - - - -
2018 - - - 12 - - - - - - - - - 10 ø - - - - -

Regional total 2014 131 0 0 31 7 0 0 0 0 5 0 0 100 11 062 2 640 5 1 13 1 206 0

2015 2 144 0 0 7 3 0 0 0 0 507 0 0 286 1 537 7 896 45 1 036 32 225 3
2016 178 0 0 67 283 0 200 0 500 1 056 0 10 0 597 579 1 22 21 31 65
2017 20 741 0 0 30 11 0 0 0 0 9 820 21 5 0 5 066 1 727 37 18 13 34 2 975
2018 17 454 0 0 51 125 0 0 0 2 000 718 0 3 132 8 557 9 193 30 1 599 111 160 175

OCEANIA
Australia 2014 - - - 457 - - 57 ø - 20 ø - ø - ø ø - 11 - 73
2015 - - - 457 - - 281 - - 139 12 - 1 - - ø - 72 - ø
2016 ø - - 1 123 - - 290 - 804 ø - - - - - - - 1 046 - -
2017 - - - 5 925 - - 450 - 3 877 4 250 - 225 - - 10 - 142 - -
New Zealand 2015 3 - - 952 - - - - - - - - - - - - ø 61 - -
2016 ø - - 1 228 - - - - - - - - - - - - ø - 9 -
2017 ø - - 562 ø - - - - - - - - - - - - 25 ø -
2018 1 - - 412 ø - - - - - - - - - - - - 10 ø -

Regional total 2014 0 0 0 457 0 0 57 0 0 20 0 0 0 0 1 0 0 11 0 184

2015 3 0 0 1 409 0 0 281 0 0 139 12 0 1 0 0 1 0 133 0 73
2016 1 0 0 2 352 0 0 290 0 804 0 0 0 0 0 0 0 0 1 046 9 0
2017 0 0 0 6 487 0 0 450 0 3 877 4 250 0 225 0 0 10 0 167 0 0
2018 1 0 0 412 0 0 0 0 0 0 0 0 0 0 0 0 0 10 0 0
 Country or territory Year

(kilograms)
(kilograms)
(kilograms)
(kilograms)b
Safrole (litres)

Isosafrole (litres)
propanone (litres)

(ANPP)a (kilograms)
Ergotamine (grams)

Ergometrine (grams)
Lysergic acid (grams)
Piperonal (kilograms)

Ephedrine (kilograms)

Acetic anhydride (litres)

3,4-Methylenedioxyphenyl-2-
Phenylacetic acid (kilograms)
Pseudoephedrine (kilograms)

1-Phenyl-2-propanone (litres)
Pseudoephedrine preparations

4-Anilino-N-phenethylpiperidine
N-Phenethyl-4-piperidone (NPP)a

N-Acetylanthranilic acid (kilograms)

Ephedrine preparationsb (kilograms)
Norephedrine (Phenylpropanolamine)
Potassium permanganate (kilograms)

alpha-Phenylacetoacetonitrile (APAAN)c

World total 2014 45 071 0 0 33 491 3 261 0 57 2 100 14 58 0 0.00 51 066 11 062 16 653 5 173 824 351 2 002 185
2015 31 169 0 0 25 982 224 0 281 0 472 689 18 0 16 922 1 537 29 840 46 138 837 1 182 228 77
2016 135 184 0 52 5 834 25 228 0 490 1 5 198 1 434 0 10 59 597 22 512 289 585 072 1 395 4 024 2 169
2017 126 900 0 0 6 786 1 283 0 450 0 4 229 9 839 272 5 19 664 5 066 4 182 48 103 657 1 019 3 057 3 007
2018 188 309 1 233 275 31 836 6 084 449 168 0 2 594 735 7 3 12 027 19 605 36 305 30 82 925 1 108 178 175

a
Included in Table I of the 1988 Convention, effective 18 October 2017.
b
Seizures of ephedrine and pseudoephedrine reported to the Board in consumption units (such as tablets and doses) have not been converted into kilograms, as the actual quantity of ephedrine and pseudoephedrine
is not known. The following countries and territories listed in the table below have reported seizures of preparations containing ephedrine and/or pseudoephedrine quantified in terms of consumption units.

Ephedrine preparations Pseudoephedrine preparations

Country Year
(units) (units)

Canada 2015 30 433 907

2016 9 757 657 45
China, Hong Kong SAR 2016 11 050 –
2018 10 –
Germany 2015 – 1 779
Hungary 2016 21 –
India 2015 560 3 342 792
Indonesia 2014 17 –
2015 – 60
Lebanon 2014 47 7 662
Annex III  71
 Ephedrine preparations Pseudoephedrine preparations
Country Year
(units) (units)

Myanmar 2018 450 000 –

Portugal 2016 – 2
Republic of Moldova 2014 – 60
2015 – 60
2016 – 60
Sweden 2016 6 363 –
Switzerland 2014 185 –
United Kingdom 2016 2 350 –
c
Included in Table I of the 1988 Convention, effective 6 October 2014.
72   INCB REPORT ON PRECURSORS 2019

d
For statistical purposes, the data for China do not include those for Hong Kong, China, or Macao, China.
e
Since 17 May 2016, “Czechia” has replaced “Czech Republic” as the short name used in the United Nations.
Table B. Seizures of substances in Table II of the 1988 Convention as reported to the International Narcotics Control Board, 2014–2018

Country or territory Year

(litres)
(litres)
(litres)

(kilograms)
Sulphuric acid

Acetone (litres)
Toluene (litres)

Anthranilic acid
Piperidine (litres)

Hydrochloric acid

Ethyl ether (litres)

Methyl ethyl ketone
AFRICA
Namibia 2016 - - - - - - - 47 355
Nigeria 2015 - - - - - - - ø
2016 979 - - 3 - - - 785
2018 203 - - 30 - - 120 319
United Republic of Tanzania 2017 25 - 173 293 20 - 730 30

Regional total 2014 0 0 0 0 0 0 0 0

2015 0 0 0 0 0 0 0 0
2016 979 0 0 3 0 0 0 48 140
2017 25 0 173 293 20 0 730 30
2018 203 0 0 30 0 0 120 319

AMERICAS
CENTRAL AMERICA AND THE CARIBBEAN
Guatemala 2017 4 - - - - - - -
Honduras 2016 22 - - 8 - - 1 -

Regional total 2014 0 0 0 0 0 0 0 0

2015 0 0 0 0 0 0 0 0
2016 22 0 0 8 0 0 1 0
2017 4 0 0 0 0 0 0 0
2018 0 0 0 0 0 0 0 0

NORTH AMERICA
Canada 2014 940 - - 219 - - 153 645
2015 ø ø - ø ø - ø -
2016 215 - - 317 - - 41 246
2018 ø - - - - - - -
Annex III  73
 Country or territory Year

(litres)
(litres)
(litres)

(kilograms)
Sulphuric acid
Toluene (litres)

Acetone (litres)
Anthranilic acid
Piperidine (litres)

Hydrochloric acid

Ethyl ether (litres)

Methyl ethyl ketone
Mexico 2014 2 402 - ø 8 446 281 - 1 406 4 324
2015 8 117 - - 188 256 184 - 4 508 26 643
2016 21 035 - - 26 573 89 - 2 502 48 172
2017 25 426 - 404 81 408 40 - 2 290 93 139
74   INCB REPORT ON PRECURSORS 2019

2018 6 236 - - 14 604 - - 8 390 14 316

United States of America 2014 4 477 - 277 1 326 11 57 1 72
2015 3 810 - 168 1 325 18 - 1 244 41
2016 121 580 - 833 105 991 3 ø - -
2017 636 - 224 335 4 121 271 56
2018 256 - 26 214 - - 191 ø

Regional total 2014 7 819 0 278 9 991 292 57 1 560 5 041

2015 11 927 0 168 189 581 202 0 5 752 26 684
2016 142 830 0 833 132 881 92 0 2 543 48 418
2017 26 062 0 628 81 743 44 121 2 561 93 195
2018 6 492 0 26 14 818 0 0 8 581 14 317

SOUTH AMERICA
Argentina 2014 67 - 77 24 677 - - 50 -
2015 8 001 - 72 54 250 12 - 4 145 71 478
2016 20 599 - 10 11 989 4 680 - 1 431 400
2017 19 834 - 4 231 1 330 - 4 028 1 403
2018 459 - 54 19 383 9 - 6 523 1 135
Bolivia (Plurinational State of) 2014 18 830 - 1 112 5 700 - - 56 283 126
2015 45 869 - 12 309 5 722 - - 51 837 160
2016 32 937 - 14 570 25 832 245 - 47 795 -
2017 7 667 - - 18 126 - - 40 817 -
2018 83 080 - - 7 832 - - 31 740 -
Brazil 2014 154 - - 15 319 - - 399 -
2015 1 081 - 313 374 679 - - 317 998 -
2016 421 - 1 1 210 - - 2 529 3 011
2017 201 - 1 107 - - 3 200
2018 335 - 387 126 - - 490 -
 Country or territory Year

(litres)
(litres)
(litres)

(kilograms)
Sulphuric acid

Acetone (litres)
Toluene (litres)

Anthranilic acid
Piperidine (litres)

Hydrochloric acid

Ethyl ether (litres)

Methyl ethyl ketone
Chile 2014 25 - 4 226 - - 233 -
2015 ø - - 142 14 - 196 ø
2016 2 - - 95 - - 73 -
2017 1 - - 1 278 - - 234 -
2018 2 040 - - 139 49 - 644 ø
Colombia 2014 456 643 - 2 117 75 058 6 155 - 276 004 191 390
2015 613 920 - 11 697 211 090 172 - 282 853 56 221
2016 946 102 - 927 208 676 22 807 - 504 970 379 495
2017 1 091 435 - 27 98 380 16 956 - 411 933 106 710
2018 1 501 098 - 8 998 171 618 15 126 - 661 983 217 854
Ecuador 2014 - - - 154 - - 708 -
2015 - - - 11 - - 2 642 -
2016 - - - 40 927 - - 4 831 -
2017 - - - - 24 - 1 400 -
2018 - - - - - - 3 380 -
Peru 2014 83 006 - 4 58 907 1 225 - 87 305 3 128
2015 55 229 - - 9 904 - - 16 576 -
2016 114 318 - - 49 203 976 - 68 354 1 795
2018 19 440 - - 1 011 76 - 1 500 4 351
Uruguay 2016 2 - - - - - - -
Venezuela (Bolivarian Republic of) 2014 27 598 - - 1 061 99 - 831 301
2015 203 824 - - 19 318 - - 10 411 10 666
2016 2 018 - - 2 948 75 - 18 726 1 982
2017 28 400 - - 21 108 249 - 15 331 25
2018 34 639 - 3 17 324 ø - 16 009 5 502

Regional total 2014 586 323 0 3 313 181 101 7 479 0 421 813 194 946
2015 927 924 0 24 391 675 116 198 0 686 659 138 525
2016 1 116 399 0 15 509 340 881 28 783 0 648 708 386 683
2017 1 147 538 0 31 139 230 18 559 0 473 745 108 338
2018 1 641 091 0 9 441 217 432 15 261 0 722 268 228 843
Annex III  75
 Country or territory Year

(litres)
(litres)
(litres)

(kilograms)
Sulphuric acid
Toluene (litres)

Acetone (litres)
Anthranilic acid
Piperidine (litres)

Hydrochloric acid

Ethyl ether (litres)

Methyl ethyl ketone
ASIA
EAST AND SOUTH-EAST ASIA
Chinaa 2014 139 171 816 7 918 1 659 718 640 - 679 966 290 917
2015 9 768 9 575 909 565 575 727 - 177 115 91 804
76   INCB REPORT ON PRECURSORS 2019

2016 32 658 2 1 412 483 284 - - 75 212 188 454

2018 - - 12 204 2 280 230 1 906 - 314 292 361 954
China, Hong Kong SAR 2016 3 - - - - - - -
Indonesia 2014 ø - - 2 376 - - 1 015 506
2015 20 - - 29 - - 63 19
2016 11 - - 30 - - 14 6
2017 5 - - ø - - ø ø
Malaysia 2014 139 - 13 779 - - - 153
2015 194 - 3 283 - - - 513
2016 - - 3 74 - - - 875
2017 173 - 5 215 - - - -
2018 792 - 14 179 - - - 835
Myanmar 2014 193 922 - - 1 687 325 - - 6 716 899 2 452 409
2016 1 238 - 250 3 495 - - 28 476 -
2017 - - - 106 720 - - 11 035 -
2018 71 540 2 100 203 794 181 657 7 860 - 62 135 4 602
Philippines 2014 ø - - ø - - - 640
2015 217 - - 283 - - 5 1 293
2016 221 - - 200 - - 2 55
2017 - - - 46 ø - 23 514
2018 2 389 - - 1 097 - - 5 2
Singapore 2014 20 - - - - - - -
2016 ø - - - 2 - - -

Regional total 2014 333 253 816 7 931 3 350 198 640 0 7 397 880 2 744 624
2015 10 199 9 575 911 566 170 727 0 177 183 93 629
2016 34 131 2 1 665 487 083 2 0 103 705 189 390
2017 177 0 5 106 981 0 0 11 058 514
2018 74 720 2 100 216 012 2 463 163 9 766 0 376 432 367 393
 Country or territory Year

(litres)
(litres)
(litres)

(kilograms)
Sulphuric acid
Toluene (litres)

Acetone (litres)
Anthranilic acid
Piperidine (litres)

Hydrochloric acid

Ethyl ether (litres)

Methyl ethyl ketone
SOUTH ASIA
India 2014 - - - - 110 364 - - -
2015 - - - - 32 - - -
2018 - - - - - - - 83
Regional total 2014 0 0 0 0 110 364 0 0 0
2015 0 0 0 0 32 0 0 0
2016 0 0 0 0 0 0 0 0
2017 0 0 0 0 0 0 0 0
2018 0 0 0 0 0 0 0 83

WEST ASIA
Afghanistan 2014 - - - 5 317 - - 19 075 25
2015 - - - - - - 15 900 363
2016 502 - - 269 - - 48 450
2017 - - - 2 260 - - - -
2018 20 146 - - 1 313 - - 122 72 185
Armenia 2014 - - ø ø - - - -
2015 ø - - ø - - ø ø
2016 ø - - ø - - - -
2017 - - - ø - - ø -
2018 ø - - ø - - ø -
Iran (Islamic Republic of) 2018 - - - - 248 - - -
Jordan 2016 - - 7 500 15 - - 30 -
2018 - - 619 12 124 - - 1 368 -
Kazakhstan 2016 - - - 1 - - 6 -
2017 ø - - 1 - - 4 -
2018 - - - - - - 9 -
Kyrgyzstan 2014 - - - 535 - - 12 756 -
2015 - - - 404 - - 8 144 -
2016 - - - 11 - - 1 926 -
2018 - - - 1 342 - - 876 -
Lebanon 2014 32 - 43 10 - - - -
Annex III  77

2016 - - 240 1 - - - -
 Country or territory Year

(litres)
(litres)
(litres)

(kilograms)
Sulphuric acid
Toluene (litres)

Acetone (litres)
Anthranilic acid
Piperidine (litres)

Hydrochloric acid

Ethyl ether (litres)

Methyl ethyl ketone
Lebanon (continued) 2017 - - 10 - - - - -
2018 10 - 22 - - - - -
Pakistan 2014 - - - 9 996 - - 27 367 -
2015 - - - 30 - - - -
78   INCB REPORT ON PRECURSORS 2019

2016 - - - - - - 2 835 -
2017 975 - - 4 130 130 - 50 595 580
2018 8 819 - - 1 737 - - 20 586 44
Tajikistan 2016 - - - - - - 20 064 -
2017 - - - - - - 300 -
2018 - - - - - - 17 -
United Arab Emirates 2018 - - - 5 250 - - 540 40
Uzbekistan 2014 - - - - - - 1 610 -
2015 10 500 - - - - - 7 800 -
2016 2 - - - - - - -
2017 23 - - - - - - -

Regional total 2014 32 0 43 15 859 0 0 60 809 25

2015 10 500 0 0 435 0 0 31 844 363
2016 504 0 7 740 297 0 0 24 909 450
2017 999 0 10 6 391 130 0 50 898 580
2018 28 975 0 641 21 765 248 0 23 518 72 269

EUROPE
STATES NOT MEMBERS OF THE EUROPEAN UNION
Bosnia and Herzegovina 2018 ø - - - - - 3 -
Belarus 2014 94 - - - - - - -
2015 2 931 - - 16 329 - - - 1 104
2016 - - - - - - 2 180 -
2017 - - - - 23 824 - - -
2018 - - - - - - ø -
Republic of Moldova 2015 - - - 2 - - ø -
2017 - - - ø - - - -
 Country or territory Year

(litres)
(litres)
(litres)

(kilograms)
Sulphuric acid
Toluene (litres)

Acetone (litres)
Anthranilic acid
Piperidine (litres)

Hydrochloric acid

Ethyl ether (litres)

Methyl ethyl ketone
Norway 2015 - - - - - - - ø
2018 2 - - - - - 6 3
Russian Federation 2014 - - - 1 - - 7 -
2015 - - - 1 - - 14 -
2017 17 - - 143 - - 4 -
2018 - - - 515 - - - -
Ukraine 2015 4 275 - - 182 - - 35 24 180
2016 113 - - 142 - - 10 12 097
2017 92 - - 354 - - 1 220 24
2018 18 399 - - 469 - - 9 079 23

Regional total 2014 94 0 0 1 0 0 7 0

2015 7 206 0 0 16 514 0 0 49 25 284
2016 113 0 0 142 0 0 2 189 12 097
2017 109 0 0 497 23 824 0 1 224 24
2018 18 399 0 0 984 0 0 9 080 23

STATES MEMBERS OF THE EUROPEAN UNION

Austria 2014 ø - - 18 - - 121 73
2015 7 - - 9 - - 5 4
2016 1 - - 1 - - ø 4
2017 1 - - 12 - - ø 4
2018 1 - 1 2 - - 2 12
Cyprus 2014 - - - ø - - - -
Czechiab 2014 1 380 - - 822 - - - 1 571
2016 - - - 5 - - 222 9
2017 159 - - 346 - - - 3 943
2018 305 - - 247 - - - 904
Estonia 2015 - - - ø - - ø -
2016 ø - - ø - - 1 -
2017 3 - - ø - - - -
2018 7 - - 1 - - 32 -
Annex III  79
 Country or territory Year

(litres)
(litres)
(litres)

(kilograms)
Sulphuric acid
Toluene (litres)

Acetone (litres)
Anthranilic acid
Piperidine (litres)

Hydrochloric acid

Ethyl ether (litres)

Methyl ethyl ketone
Germany 2014 10 - - 6 - - 27 17
2015 18 - - 6 - - 32 2
2016 20 - - 11 - - 4 -
2018 3 249 - - 3 097 10 - 2 122 169
80   INCB REPORT ON PRECURSORS 2019

Hungary 2014 12 - - ø - - ø -
2015 26 - - - - - - 23
2016 2 - - - - - - -
2017 17 - 1 - - - 3 1
2018 7 - - 8 - - 3 13
Italy 2017 - - - - - - - 110
2018 13 - - - 497 - 15 4 252
Latvia 2018 468 - 136 68 - - ø -
Lithuania 2015 - - 2 - - - - -
Netherlands 2014 8 510 - - 13 825 - - 6 555 -
2015 20 887 - 812 20 266 409 - 28 265 465
2016 28 074 - 145 40 935 - - 8 748 1 098
2017 9 272 - 140 29 013 2 858 - 4 433 25
2018 21 226 - 45 36 066 6 602 - 8 386 1 310
Poland 2014 130 - - 8 - - 11 196
2015 - - - 121 - - 57 7
2016 8 - - 104 - - 440 23
2017 315 - - 157 - - 57 147
Portugal 2015 64 - 5 9 - - - -
2016 - - - ø - - - -
2017 3 - - 1 - - - -
2018 - - - - 18 713 - - -
Romania 2016 4 - - - - - - -
2017 ø - - - - - - -
2018 ø - - - - - - -
Slovakia 2014 ø - 1 10 - - 3 18
2015 - - - 1 - - - 43
2016 - - - 4 - - - 83
2017 - - - 61 - - - 19
2018 - - - 6 - - ø 53
 Country or territory Year

(litres)
(litres)
(litres)

(kilograms)
Sulphuric acid
Toluene (litres)

Acetone (litres)
Anthranilic acid
Piperidine (litres)

Hydrochloric acid

Ethyl ether (litres)

Methyl ethyl ketone
Spain 2014 85 - 20 159 1 - 1 2
2015 941 - 78 4 412 1 061 - 444 1
2016 1 610 - 133 1 077 101 - 569 -
2017 49 - 54 28 1 585 ø 124 466
2018 30 615 - 83 12 533 2 913 - 8 480 13
Sweden 2016 10 - - - - - - -
United Kingdom of Great
Britain and Northern Ireland 2016 - ø - - - - - -
2017 - - 42 - 3 - - -

Regional total 2014 10 221 0 21 14 851 1 0 6 724 1 878

2015 29 148 0 897 41 338 1 470 0 28 851 25 829
2016 29 842 0 278 42 280 101 0 12 174 13 314
2017 9 929 0 237 30 116 28 270 0 5 841 4 739
2018 74 294 0 264 53 013 28 735 0 28 130 6 751

OCEANIA
Australia 2015 - 2 - - - - - -
2016 - 1 - - - ø - -
2017 - ø - - - ø - -
New Zealand 2015 45 - - 313 - - 46 140
2016 71 - - 167 - - 6 77
2017 117 - - 118 - - 32 27
2018 37 - - 144 - - ø 19

Regional total
2014 0 0 0 0 0 0 0 0
2015 45 2 0 313 0 0 46 140
2016 71 1 0 167 0 0 6 77
2017 117 1 0 118 0 0 32 27
2018 37 0 0 144 0 0 0 19

Annex III  81
 Country or territory Year

(litres)
(litres)
(litres)

(kilograms)
Sulphuric acid
Toluene (litres)

Acetone (litres)
Anthranilic acid
Piperidine (litres)

Hydrochloric acid

Ethyl ether (litres)

Methyl ethyl ketone
World total 2014 937 648 816 11 585 3 572 000 118 776 57 7 888 787 2 946 513
2015 989 743 9 577 26 368 1 472 951 2 628 0 930 335 285 170
2016 1 324 777 3 26 025 1 003 599 28 978 0 792 045 686 472
2017 1 184 851 1 1 084 364 871 47 023 121 544 866 207 423
82   INCB REPORT ON PRECURSORS 2019

2018 1 825 812 2 100 226 384 2 770 365 54 010 0 1 159 050 689 994

a
For statistical purposes, the data for China do not include those for Hong Kong, China, and Macao, China.
b
Since 17 May 2016, “Czechia” has replaced “Czech Republic” as the short name used in the United Nations.
 Annex IV  83

Annex IV

Submission of information by Governments on licit

trade in, legitimate uses of and requirements for
­substances in Tables I and II of the United Nations
Convention against Illicit Traffic in Narcotic Drugs and
Psychotropic Substances of 1988 for the years
2014–2018
Notes: The names of non-metropolitan territories and special administrative regions are in italics.
A blank signifies that no information was provided.
“X” signifies that a completed form D (or equivalent report) was submitted (including forms in which all
fields contained “nil”, “0”, “none”, etc.).

2014 2015 2016 2017 2018

Uses Uses Uses Uses Uses
Country or territory and/or and/or and/or and/or and/or
Trade Trade Trade Trade Trade
require- require- require- require- require-
ments ments ments ments ments
Afghanistan X X X X X X X X X X
Albania X X X X X X X X X X
Algeria X X X X X X X X X
Andorra X X
Angola X X X X
Anguilla
Antigua and
Barbuda
Argentina X X X X X X X X X X
Armenia X X X X X X X X X
Aruba
Ascension Island
Australia X X X X X X X X
Austria a
X X X X X X X X X X
Azerbaijan X X X X X X X X X X
Bahamas
Bahrain X X X X X X X X X X
Bangladesh X X X X X X
Barbados
Belarus X X X X X X X X X
Belgium a
X X X X X X X X X X
Belize X X
Benin X X X X X X X X X X
Bermuda
Bhutan X X X X X X X X X X
84   INCB REPORT ON PRECURSORS 2019

2014 2015 2016 2017 2018

Uses Uses Uses Uses Uses
Country or territory and/or and/or and/or and/or and/or
Trade Trade Trade Trade Trade
require- require- require- require- require-
ments ments ments ments ments
Bolivia
(Plurinational State X X X X X X X X X X
of)
Bosnia and
X X X X X X X X X X
Herzegovina
Botswana X
Brazil X X X X X X X X X X
British Virgin
Islands
Brunei Darussalam X X X X X X X X X X
Bulgaria a
X X X X X X X X X X
Burkina Faso
Burundi X X
Cabo Verde X X X X X X X X X X
Cambodia X
Cameroon X X
Canada X X X X X X X X X X
Cayman Islands
Central African
Republic
Chad
Chile X X X X X X X X X X
China X X X X X X X
 China, Hong Kong
X X X X
SAR
 China, Macao SAR X X X X X X
Christmas Island X X
Cocos (Keeling)
X X
Islands
Colombia X X X X X X X X X X
Comoros
Congo
Cook Islands
Costa Rica X X X X X X X X X X
Côte d’Ivoire X X X X
Croatiaa X X X X X X X X X X
Cuba X
Curaçao X X X X X X X X
Cyprus X X X X X X X X X X
Czechiaa,b X X X X X X X X X X
Democratic
People’s Republic X X X X X
of Korea
Democratic
Republic of the X X X X X X X
Congo
 Annex IV  85

2014 2015 2016 2017 2018

Uses Uses Uses Uses Uses
Country or territory and/or and/or and/or and/or and/or
Trade Trade Trade Trade Trade
require- require- require- require- require-
ments ments ments ments ments
Denmarka X X X X X X X X
Djibouti
Dominica
Dominican
X X X X X X X X
Republic
Ecuador X X X X X X X X X X
Egypt X X X X X X X X X X
El Salvador X X X X X X X X X X
Equatorial Guinea
Eritrea
Estoniaa X X X X X X X X
Eswatinic
Ethiopia X X
Falkland Islands
X X X X X X
(Malvinas)
Fiji X X
Finland a
X X X X X X X X X X
France a
X X X X X X X X X X
French Polynesia X X
Gabon X
Gambia X
Georgia X X X X X X X X X X
Germany a
X X X X X X X X X X
Ghana X X X X X X X X
Gibraltar
Greecea X X X X X X X X X
Grenada
Guatemala X X X X X X X X X X
Guinea
Guinea-Bissau
Guyana X X X X X
Haiti X X X X X
Holy Seed
Honduras X X X X X X X X
Hungary a
X X X X X X X X X X
Iceland X X X X X X X X
India X X X X X X X X X X
Indonesia X X X X X X X X X
Iran (Islamic
X X X X X X X X X
Republic of)
Iraq X X
Irelanda X X X X X X X X X X
Israel X X X X X X X X X X
86   INCB REPORT ON PRECURSORS 2019

2014 2015 2016 2017 2018

Uses Uses Uses Uses Uses
Country or territory and/or and/or and/or and/or and/or
Trade Trade Trade Trade Trade
require- require- require- require- require-
ments ments ments ments ments
Italya X X X X X X X X X X
Jamaica X X X X X X X X X X
Japan X X X X X X X X X X
Jordan X X X X X X X X X X
Kazakhstan X X X X X X X X
Kenya X X X X X X
Kiribati
Kuwait X
Kyrgyzstan X X X X X X X X
Lao People’s
Democratic X X X X X X X
Republic
Latviaa X X X X X X X X X X
Lebanon X X X X X X X X X X
Lesotho X
Liberia
Libya
Liechtensteine
Lithuaniaa X X X X X X X X X X
Luxembourg a

Madagascar X X X X X X X X
Malawi X
Malaysia X X X X X X X X X X
Maldives X X
Mali
Maltaa X X X X X X X X X
Marshall Islands
Mauritania
Mauritius X X
Mexico X X X X X X X X X X
Micronesia
(Federated States
of)
Monaco X X X X X X
Mongolia X X X X X
Montenegro X X X X X X X X X X
Montserrat X X X X X X X X X
Morocco X X X X X X X X X X
Mozambique X X X
Myanmar X X X X X X X X X X
Namibia
Nauru
Nepal X X X
Netherlands a
X X X X X X X X X X
 Annex IV  87

2014 2015 2016 2017 2018

Uses Uses Uses Uses Uses
Country or territory and/or and/or and/or and/or and/or
Trade Trade Trade Trade Trade
require- require- require- require- require-
ments ments ments ments ments
New Caledonia
New Zealand X X X X X X X
Nicaragua X X X X X X X X X
Niger
Nigeria X X X X X X
Niue
Norfolk Island X X
North Macedonia f
X X
Norway X X X X X X X X
Oman X X X X X X X X
Pakistan X X X X X X X X X X
Palau
Panama X X X X X X X X X
Papua New Guinea
Paraguay X X
Peru X X X X X X X X
Philippines X X X X X X X X X X
Poland a
X X X X X X X X
Portugala X X X X X X X X X X
Qatar X X X X
Republic of Korea X X X X X X X X X X
Republic of
X X X X X X X X X X
Moldova
Romaniaa X X X X X X X X X X
Russian Federation X X X X X X X X X X
Rwanda X X
Saint Helena
Saint Kitts and
Nevis
Saint Lucia X X X X X X X X X
Saint Vincent and
X X X X X X X X
the Grenadines
Samoa
San Marinod
Sao Tome and
Principe
Saudi Arabia X X X X X X X X X X
Senegal X X X X X X X
Serbia X X X X X X
Seychelles X X
Sierra Leone X
Singapore X X X X X X X
Sint Maarten
Slovakiaa X X X X X X X X X X
88   INCB REPORT ON PRECURSORS 2019

2014 2015 2016 2017 2018

Uses Uses Uses Uses Uses
Country or territory and/or and/or and/or and/or and/or
Trade Trade Trade Trade Trade
require- require- require- require- require-
ments ments ments ments ments
Sloveniaa X X X X X X X X X X
Solomon Islands
Somalia
South Africa X X X X X X X X
South Sudan X X X X
Spaina X X X X X X X X X X
Sri Lanka X X X X X X X X
Sudan X X X X X X X X X
Suriname X X
Sweden a
X X X X X X X X X X
Switzerland X X X X X X X X X X
Syrian Arab
X X X X X X X
Republic
Tajikistan X X X X X X X X
Thailand X X X X X X X X X X
Timor-Leste
Togo
Tonga
Trinidad and
X X X X X X X X X X
Tobago
Tristan da Cunha
Tunisia X X X X X X X X X X
Turkey X X X X X X X X X X
Turkmenistan X X X X X X
Turks and Caicos
Islands
Tuvalu
Uganda X X X X X
Ukraine X X X X X X X X
United Arab
X X X X X X X X
Emirates
United Kingdom of
Great Britain and X X X X X X X X X X
Northern Irelanda
United Republic of
X X X X X X X X X X
Tanzania
United States of
X X X X X X X X X X
America
Uruguay X X X X X X X X X X
Uzbekistan X X X X X X X X X X
Vanuatu
Venezuela
(Bolivarian X X X X X X X X X X
Republic of)
Viet Nam X X X X X X
 Annex IV  89

2014 2015 2016 2017 2018

Uses Uses Uses Uses Uses
Country or territory and/or and/or and/or and/or and/or
Trade Trade Trade Trade Trade
require- require- require- require- require-
ments ments ments ments ments
Wallis and Futuna
Islands
Yemen X X
Zambia X X
Zimbabwe X X X X X X X X
Total number of
Governments
118 116 128 124 124 120 117 113 115 109
that submitted
form D
Total number of
Governments
requested to 213 213 213 213 213 213 213 213 213 213
provide
information

a
State member of the European Union.
b
Since 17 May 2016, “Czechia” has replaced “Czech Republic” as the short name used in the United Nations.
c
Since 19 April 2018, “Eswatini” has replaced “Swaziland” as the short name used in the United Nations.
d
The Government of Italy includes on form D licit trade data for the Holy See and San Marino.
e
The Government of Switzerland includes on form D licit trade data for Liechtenstein.
f
Since 14 February 2019, “North Macedonia” has replaced “the former Yugoslav Republic of Macedonia” as the short name used in the United Nations.
90   INCB REPORT ON PRECURSORS 2019

Annex V

Annual legitimate requirements for ephedrine,

­pseudoephedrine, 3,4-methylenedioxyphenyl-2-­
propanone and 1-phenyl-2-propanone; substances
­frequently used in the manufacture of amphetamine-
type stimulants
1. In its resolution 49/3, entitled “Strengthening systems for the control of precursor chemicals used in the manufacture
of synthetic drugs”, the Commission on Narcotic Drugs:
(a) Requested Member States to provide to the International Narcotics Control Board annual estimates of their
legitimate requirements for 3,4-methylenedioxyphenyl-2-propanone (3,4-MDP-2-P), pseudoephedrine, ephedrine and
1-phenyl-2-propanone (P-2-P) and, to the extent possible, estimated requirements for imports of preparations containing
those substances that could be easily used or recovered by readily applicable means;
(b) Requested the Board to provide those estimates to Member States in such a manner as to ensure that such infor-
mation was used only for drug control purposes;
(c) Invited Member States to report to the Board on the feasibility and usefulness of preparing, reporting and using
estimates of legitimate requirements for the precursor chemicals and preparations referred to above in preventing
diversion.
2. Pursuant to that resolution, the Board formally invited Governments to prepare estimates of their legitimate
­requirements for those substances. Those estimates, as reported by Governments, were published for the first time in
March 2007.
3. The table below reflects the latest data reported by Governments on those four precursor chemicals (and their
­preparations, as relevant). It is expected that those data will provide the competent authorities of exporting countries with
at least an indication of the legitimate requirements of importing countries, thus preventing diversion attempts.
Governments are invited to review their requirements as published, amend them as necessary and inform the Board of
any required change. The data are current as at 1 November 2019; for updates, see the Board’s website.
 Annex V  91

Annual legitimate requirements as reported by Governments for imports of

ephedrine, pseudoephedrine, 3,4-methylenedioxyphenyl-2-propanone,
1-phenyl-2-propanone and their preparations, as at 1 November 2019

Pseudoephedrine prepara-
Ephedrine preparations
Ephedrine (kilograms)

3,4-MDP-2-Pa (litres)
Pseudoephedrine

tions (kilograms)

P-2-Pb (litres)
(kilograms)

(kilograms)
Country or territory

Afghanistan 0 50 1 000 2 000 0 0

Albania 40 3 10 3 0 0
Algeria 20 17 000 0 1
Argentina 54 0 19 044 144 0 0
Armenia 0 0 0 0 0 0
Ascension Island 0 0 0 0 0 0
Australia 5 8 4 800 1 680 0 1
Austria 272 22 200 1 1 1
Azerbaijan 20 10 0 0
Bahrain 1 10 1 4 000 0 0
Bangladesh 200 0 0 0
Barbados 200 200 58 0c
Belarus 0 25 20 20 0 0
Belgium 600 100 9 000 8 000 0 5
Belize P P 0c

Benin 2 5 8 35 0c
Bhutan 0 2 0 0 0 0
Bolivia 25 1 5 360 2 100 0 0
Bosnia and
25 2 9 405 1 784 0 0
Herzegovina
Botswana 300 0c
Brazil 2 000d 0 38 000d 0 0 0
Brunei Darussalam 0 1 0 145 0 0
Bulgaria 500 296 20 0 0 0
Burundi 5 15 0c

Cabo Verde 0 1 0 0 0 0
Cambodia 200 50 300 900 0c

Cameroon 25 1 0c
Canada 7 000 10 30 000 25 000 1 1
Chile 30 0 10 000 350 0 0
China 18 000 100 000 0c

 China, Hong Kong

1 101 0 4 726 0 0 0
SAR
China, Macao SAR 1 10 1 159 0 0
92   INCB REPORT ON PRECURSORS 2019

Pseudoephedrine prepara-
Ephedrine preparations
Ephedrine (kilograms)

3,4-MDP-2-Pa (litres)
Pseudoephedrine

tions (kilograms)

P-2-Pb (litres)
(kilograms)

(kilograms)
Country or territory

Christmas Island 0 0 0 1 0 0
Cocos (Keeling)
0 0 0 0 0 0
Islands
Colombia 0e 0f 4 104e P 0 0
Cook Islands 0 0 0 1 0 0
Costa Rica 0 0 625 91 0 0
Côte d’Ivoire 30 1 0 400 0 0
Croatia 40 1 5 1 1 1
Cuba 200 6 0 c

Curaçao 0 0 0 0
Cyprus 10 10 600 400 0 0
Czechia 313 6 476 374 0 1
Democratic People’s
50 1 200 4
Republic of Korea
Democratic Republic
275 8 720 487 0c
of the Congo
Denmark 0 400
Dominican Republic 75 6 300 500 0 0
Ecuador 5 8 1 200 2 135 0 0
Egypt 4 500 0 63 000 2 500 0 0
El Salvador P6 g
P6 g
P P 0 0
Eritrea 0 0 0 0 0 0
Estonia 3 5 1 500 0 0
Ethiopia 1 000 100 0 c

Falkland Islands
0 1 0 1 0c 0
(Malvinas)
Faroe Islands 0 0 0 0 0 0
Fiji 1 0 c

Finland 3 50 0 650 0 1
France 1 600 10 26 000 500 0 0
Gambia 0 0 0 0 0 0
Georgia 1 1 1 1 1 1
Germany 400 d
5 000 d
1 7
Ghana 4 500 300 3 000 200 0 0
Greece 0 0 2 000 0 0 0
Greenland 0 0 0 0 0 0
Guatemala 0 P P 0 0
Guinea 36 0 c

Guinea-Bissau 0 0 0 0 0 0
Guyana 120 50 120 30 0 0
 Annex V  93

Pseudoephedrine prepara-
Ephedrine preparations
Ephedrine (kilograms)

3,4-MDP-2-Pa (litres)
Pseudoephedrine

tions (kilograms)

P-2-Pb (litres)
(kilograms)

(kilograms)
Country or territory

Haiti 200 1 350 11 0 0

Honduras P P2 f
P P 0 0
Hungary 1 000 0 31 0 1 1 000
Iceland 0 0 0 0 0 0
India 773 201 112 729 63 953 193 801 0 0
Indonesia 13 000 1 52 000 6 200 0 0
Iran (Islamic
2 1 17 000 1 1 1
Republic of)
Iraq 3 000 100 14 000 10 000 0 Ph
Ireland 0 25 1 1 252 0 0
Israel 28 0 5 000 350 0c
Italy 100 100 10 000 30 000 0 0
Jamaica 70 150 550 300 0 0
Japan 5 000 12 000 0c

Jordan 100 40 000 0 P

Kazakhstan 11 1 10 1 1 1
Kenya 1 500 2 000 1 500 2 000 0 0
Kyrgyzstan 0 1 000 0 5 000 0 0
Lao People’s
0 0 0 0 0 0
Democratic Republic
Latvia 23 15 45 180 0 0
Lebanon 25 2 800 800 0 0
Lithuania 0 1 0 700 0 1
Luxembourg 1 0 0 0 0 0
Madagascar 123 35 1 135 0 0
Malawi 1 000 0c

Malaysia 42 20 4 500 5 000 0 0

Maldives 0 1 0 0 0 0
Mali P P P P P P
Malta 0 220 0 220 0 0
Mauritius 0 1 0 130 0 0
Mexico P 231 g
P g
P P 0 0
Monaco 0 0 0 0 0 0
Mongolia 0 0 0 0 0 0
Montenegro 0 2 0 200 0 0
Montserrat 0 0 0 1 0 0
Morocco 41 16 2 529 0 0 0
Mozambique 3 0c

Myanmar 15 25 0 0 0 0
94   INCB REPORT ON PRECURSORS 2019

Pseudoephedrine prepara-
Ephedrine preparations
Ephedrine (kilograms)

3,4-MDP-2-Pa (litres)
Pseudoephedrine

tions (kilograms)

P-2-Pb (litres)
(kilograms)

(kilograms)
Country or territory

Namibia 0 0 0 0 0 0
Nepal 1 5 000 0c

Netherlands 200 50 1 675 0 0 1

New Zealand 120 0 1 000 0 3
Nicaragua Pi
P
i
P P 0 0
Nigeria 9 650 500 5 823 15 000 0 0
Norfolk Island 0 0 0 0 0 0
Norway 30 1 1 0 1
Oman 1 1 228 443 0c

Pakistan 8 400 52 800 500 0c

Panama 0 5 200 200 0
Papua New Guinea 1 200 0 0
Paraguay 0 0 2 500 0 0 0
Peru 45 0 2 524 1 078 0 0
Philippines 50 0 100 0 0 0
Poland 310 100 7 500 3 000 3 4
Portugal 13 0 700 0 0 0
Qatar 0 2 0 800 0 0
Republic of Korea 37 274 38 192 0 198
Republic of
0 1 326 199 0 0
Moldova
Romania 118 10 870 0 0 1
Russian Federation 1 500 0c
Rwanda 10 10 2 2
Saint Helena 0 1 0 1 0 0
Saint Lucia 0 6 0 15 0 0
Saint Vincent and
0 2 0 2 0 0
the Grenadines
Sao Tome and
0 0 0 0 0 0
Principe
Saudi Arabia 1 0 40 000 0 0 0
Senegal 123 1 0 130 0 0
Serbia 1.8 1 2 214 627 0 1
Seychelles 1 1 0c

Sierra Leone 70 10 000

Singapore 7 000 45 25 000 2 800 1 1
Slovakia 58 1 1 1 0 0
Slovenia 374 23 250 246 0 0
Solomon Islands 0 1 0 1 0 0
 Annex V  95

Pseudoephedrine prepara-
Ephedrine preparations
Ephedrine (kilograms)

3,4-MDP-2-Pa (litres)
Pseudoephedrine

tions (kilograms)

P-2-Pb (litres)
(kilograms)

(kilograms)
Country or territory

South Africa 1 544 22 10 554 681 0 0

South Sudan 750 1 500 0c

Spain 234 10 198 0 3 193

Sri Lanka 0 0 0 0 0 0
Sudan 500 1 000 2 000 3 500 0
Suriname 1 0c
Sweden 209 175 1 1 1 11
Switzerland 1 500 5 85 000 200 10 5
Syrian Arab
1 000 50 000 0c
Republic
Tajikistan 38 0c
Thailand 60 0 3 600 0 0 5
Trinidad and
0c 0
Tobago
Tristan da Cunha 0 0 0 0 0 0
Tunisia 2 12 3 000 1 0 30
Turkey 250 0 32 000 200 0 0
Turkmenistan 0 0 0 0 0 0
Uganda 1 000 35 5 500 800 0c 0
Ukraine 0 67 23 0 0 0
United Arab
0 0 1 533 3 894 0 0
Emirates
United Kingdom of
Great Britain and 1 503 27 37 690 20 002 0 2
Northern Ireland
United Republic of
100 1 500 2 000 200 0c
Tanzania
United States of
4 183 180 001 0c 53 436
America
Uruguay 21 0 0 0 0 0
Uzbekistan 0 0 0 0 0 0
Venezuela
(Bolivarian Republic 60 0 2 075 0 0 0
of)
Yemen 200 200 5 000 1 000 0c
Zambia 50 25 50 100 0c
Zimbabwe 25 1 400 50 0 0

Notes: The names of territories, departments and special administrative regions are in italics.
  A blank field signifies that no requirement was indicated or that data were not submitted for the substance in question.
  A zero (0) signifies that the country or territory currently has no licit requirement for the substance.
  The letter “P” signifies that importation of the substance is prohibited.
  Reported quantities of less than 1 kg have been rounded up and are reflected as 1 kg.
96   INCB REPORT ON PRECURSORS 2019

a
3,4-Methylenedioxyphenyl-2-propanone.
b
1-Phenyl-2-propanone.
c
The Board is currently unaware of any legitimate need for the importation of this substance into the country.
d
Including the licit requirements for pharmaceutical preparations containing the substance.
e
The required amount of ephedrine is to be used for the manufacture of injectable ephedrine sulphate solution. The required amount of pseu-
doephedrine is to be used exclusively for the manufacture of medicines for export.
f
In the form of injectable ephedrine sulfate solution.
g
Imports of the substance and preparations containing the substance are prohibited, with the exception of the imports of injectable ephedrine
preparations and ephedrine as a prime raw material for the manufacture of such ephedrine preparations. Pre-export notification is required for each
individual import.
h
Includes products containing P-2-P.
i
Imports of the substance and preparations containing the substance are prohibited, with the exception of the imports of injectable ephedrine
preparations and ephedrine as a prime raw material for the manufacture of such ephedrine preparations. Such import requires an import permit.
 Annex VI  97

Annex VI

Governments that have requested pre-export

­notifications pursuant to article 12, subparagraph 10 (a),
of the United Nations Convention against Illicit Traffic in
Narcotic Drugs and Psychotropic Substances of 1988
1. Governments of all exporting countries and territories are reminded that it is an obligation to provide pre-export
notifications to Governments that have requested them pursuant to article 12, subparagraph 10 (a), of the United Nations
Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances of 1988, which provides that:
 “upon request to the Secretary-General by the interested Party, each Party from whose territory a substance in
Table I is to be exported shall ensure that, prior to such export, the following information is supplied by its competent
authorities to the competent authorities of the importing country:
“(i) Name and address of the exporter and importer and, when available, the consignee;
“(ii) Name of the substance in Table I;
“(iii) Quantity of the substance to be exported;
“(iv) Expected point of entry and expected date of dispatch;
“(v) Any other information which is mutually agreed upon by the Parties.”

2. Governments that have requested pre-export notifications are listed in the table below in alphabetical order, followed
by the substance (or substances) for which pre-export notifications were requested, and the date of notification of the
request transmitted by the Secretary-General to Governments.
3. The information is current as at 1 November 2019.

Date of communication to
Substances for which pre-export notifications
Notifying Government Governments by the
have been requested
Secretary-General
Afghanistana All substances included in Tables I and II 13 July 2010
Algeria a
All substances included in Tables I and II 10 October 2013
Antigua and Barbuda a
All substances included in Tables I and II 5 May 2000
Argentina All substances included in Table I 19 November 1999
Armenia a
All substances included in Tables I and II b,c
4 July 2013
Australia a
All substances included in Tables I and II 12 February 2010
Austria All substances included in Table I 19 May 2000d
Azerbaijana All substances included in Tables I and II 21 January 2011
Bangladesha All substances included in Tables I and II 12 May 2015
Barbadosa All substances included in Tables I and IIb,c 24 October 2013
Belaruse Acetic anhydride, ephedrine, potassium permanga- 12 October 2000
nate and pseudoephedrine
Belgium All substances included in Table I 19 May 2000
Benin a
All substances included in Tables I and II 4 February 2000
Bhutan a
All substances included in Tables I and II 6 July 2018
Bolivia (Plurinational State of) a
Acetic anhydride, acetone, ethyl ether, hydrochloric 12 November 2001
acid, potassium permanganate and sulphuric acid
98   INCB REPORT ON PRECURSORS 2019

Date of communication to
Substances for which pre-export notifications
Notifying Government Governments by the
have been requested
Secretary-General
Brazila All substances included in Tables I and II 15 October 1999 and 15 December
1999
Bulgaria All substances included in Table I 19 May 2000d
Canadaa All substances included in Tables I and II 31 October 2005
Cayman Islands a
All substances included in Tables I and II 7 September 1998
Chile a
All substances included in Tables I and II 19 October 2012
China Acetic anhydride 20 October 2000
China, Hong Kong SAR a
All substances included in Tables I and II 28 December 2012
China, Macao SARa All substances included in Tables I and II 28 December 2012
Colombia a
All substances included in Tables I and II 14 October 1998
Costa Rica a
All substances included in Tables I and II 27 September 1999
Côte d’Ivoire a
All substances included in Tables I and II 26 June 2013
Croatia All substances included in Table I 19 May 2000d
Cyprus All substances included in Table I 19 May 2000d
Czechiaf All substances included in Table I 19 May 2000d
Denmark All substances included in Table I 19 May 2000d
Dominican Republica All substances included in Tables I and II 11 September 2002
Ecuador a
All substances included in Tables I and II 1 August 1996
Egypt a
All substances included in Table I and acetone 3 December 2004
El Salvador a
All substances included in Tables I and II 29 July 2010
Estonia All substances included in Table I 19 May 2000
Ethiopiaa All substances included in Tables I and II 17 December 1999
European Union (on behalf of All substances included in Table I 19 May 2000d
all its States members)g
Finland All substances included in Table I 19 May 2000d
France All substances included in Table I 19 May 2000d
Georgiaa All substances included in Tables I and II 7 September 2016
Germany All substances included in Table I 19 May 2000d
Ghana a
All substances included in Tables I and II 26 February 2010
Greece All substances included in Table I 19 May 2000d
Haitia All substances included in Tables I and II 20 June 2002
Hungary All substances included in Table I 19 May 2000d
Indiaa All substances included in Tables I and II 23 March 2000
Indonesia a
Acetic anhydride, N-acetylanthranilic acid, 18 February 2000
anthranilic acid, ephedrine, ergometrine,
­ergotamine, isosafrole, 3,4-methylenedioxyphenyl-
2-propanone, phenylacetic acid, 1-phenyl-2-­
propanone, piperonal, pseudoephedrine and safrole
Iraqa All substances included in Tables I and IIb,c 31 July 2013
Ireland All substances included in Table I 19 May 2000d
Italy All substances included in Table I 19 May 2000d
Jamaica All substances included in Table Ib,c 4 July 2013
Japan All substances included in Table I 17 December 1999
Jordan a
All substances included in Tables I and II 15 December 1999
 Annex VI  99

Date of communication to
Substances for which pre-export notifications
Notifying Government Governments by the
have been requested
Secretary-General
Kazakhstana All substances included in Tables I and II 15 August 2003
Kenya a
All substances included in Tables I and II b,c
10 October 2013
Kyrgyzstan a
All substances included in Tables I and II b,c
21 October 2013
Latvia All substances included in Table I 19 May 2000d
Lebanona All substances included in Tables I and II 14 June 2002
Lithuania All substances included in Table I 19 May 2000d
Luxembourg All substances included in Table I 19 May 2000d
Libyaa All substances included in Tables I and IIb,c 21 August 2013
Madagascara All substances included in Tables I and II 31 March 2003
Malaysiaa All substances included in Table I,b anthranilic acid, 21 August 1998
ethyl ether, piperidine
Maldivesa All substances included in Tables I and II 6 April 2005
Malta All substances included in Table I 19 May 2000d
Mexicoa All substances included in Tables I and II 6 April 2005
Micronesia (Federated States All substances included in Tables I and IIb,c 11 February 2014
of)a
Myanmara All substances included in Tables I and II 4 November 2016
Netherlands All substances included in Table I 19 May 2000d
New Zealanda All substances included in Tables I and IIb,c 3 April 2014
Nicaragua a
All substances included in Tables I and II 8 January 2014
Nigeriaa All substances included in Tables I and II 28 February 2000
Norwaya All substances included in Table I,c and anthranilic 17 December 2013
acid, ethyl ether and piperidine
Omana All substances included in Tables I and II 16 April 2007
Pakistana All substances included in Tables I and II 12 November 2001 and 6 March 2013
Panama Ephedrine, ergometrine, ergotamine, norephedrine, 14 August 2013
pseudoephedrine
Paraguaya All substances included in Tables I and II 3 February 2000
Peru a
Acetic anhydride, acetone, ephedrine, ergometrine, 27 September 1999
ergotamine, ethyl ether, hydrochloric acid, lysergic
acid, methyl ethyl ketone, norephedrine, potassium
permanganate, pseudoephedrine, sulphuric acid
and toluene
Philippinesa All substances included in Tables I and II 16 April 1999
Poland All substances included in Table I 19 May 2000d
Portugal All substances included in Table I 19 May 2000d
Qatara All substances included in Tables I and IIb,c 16 July 2013
Republic of Koreaa All substances included in Table I, and acetone 3 June 2008
Republic of Moldovaa All substances included in Tables I and IIb,c 29 December 1998 and 8 November
2013
Romania All substances included in Table I 19 May 2000d
Russian Federationa Acetic anhydride, ephedrine, ergometrine, ergotamine, 21 February 2000
3,4-methylenedioxyphenyl-2-propanone, norephedrine,
phenylacetic acid, 1-phenyl-2-­propanone, potassium
permanganate, ­pseudoephedrine and all substances
included in Table II
100   INCB REPORT ON PRECURSORS 2019

Date of communication to
Substances for which pre-export notifications
Notifying Government Governments by the
have been requested
Secretary-General
Saint Vincent and the All substances included in Tables I and IIb,c 16 July 2013
Grenadinesa
Saudi Arabiaa All substances included in Tables I and II 18 October 1998
Sierra Leone a
All substances included in Tables I and II b,c
5 July 2013
Singapore All substances included in Table I 5 May 2000
Slovakia All substances included in Table I 19 May 2000d
Slovenia All substances included in Table I 19 May 2000d
South Africaa All substances included in Table I, and anthranilic 11 August 1999
acid
Spain All substances included in Table I 19 May 2000d
Sri Lanka All substances included in Table I 19 November 1999
Sudan a
All substances included in Tables I and II 6 May 2015
Syrian Arab Republic a
All substances included in Tables I and II 24 October 2013
Sweden All substances included in Table I 19 May 2000d
Switzerland All substances included in Table I 25 March 2013
Tajikistan a
All substances included in Tables I and II 7 February 2000
Thailand a
All substances included in Table I (except potassium 18 October 2010
permanganate), and anthranilic acidb
Togoa All substances included in Tables I and II 6 August 2013
Tonga a
All substances included in Tables I and II b,c
4 July 2013
Trinidad and Tobago a
All substances included in Tables I and II b,c
15 August 2013
Turkey a
All substances included in Tables I and II 2 November 1995
Uganda a
All substances included in Tables I and II b,c
6 May 2014
United Arab Emirates a
All substances included in Tables I and II
b
26 September 1995
United Kingdom of Great All substances included in Table I 19 May 2000d
Britain and Northern Ireland
United Republic of Tanzaniaa All substances included in Tables I and II 10 December 2002
United States of America Acetic anhydride, ephedrine and pseudoephedrine 2 June 1995 and 19 January 2001
Uruguay a
All substances included in Tables I and II 30 December 2015
Venezuela (Bolivarian All substances included in Tables I and II 27 March 2000
Republic of)a
Yemena All substances included in Tables I and II 6 May 2014
Zimbabwea All substances included in Tables I and IIb,c 4 July 2013
Note: The names of territories are in italics.
a
The Secretary-General has informed all Governments of the request of the notifying Government to also receive a pre-export notification for some
or all substances listed in Table II of the 1988 Convention.
b
The Government requested to also receive pre-export notifications for pharmaceutical preparations containing ephedrine and pseudoephedrine.
c
The Government requested to also receive pre-export notifications for safrole-rich oils.
d
On 19 May 2000, the Secretary-General communicated to Governments the request by the European Commission on behalf of the States ­members
of the European Union to receive pre-export notifications for the indicated substances.
e
Not yet notified by the Secretary-General, as, in a subsequent communication, the Government of Belarus requested the Secretary-General to
suspend such notification until a national mechanism to receive and process pre-export notifications was established.
f
Since 17 May 2016, “Czechia” has replaced “Czech Republic” as the short name used in the United Nations.
g
Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia,
Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and United Kingdom of Great Britain and
Northern Ireland.
 Annex VII  101

Annex VII

Substances in Tables I and II of the United Nations

Convention against Illicit Traffic in Narcotic Drugs and
Psychotropic Substances of 1988

Table I Table II
Acetic anhydride Acetone
N-Acetylanthranilic acid Anthranilic acid
4-Anilino-N-phenethylpiperidine (ANPP) a
Ethyl ether
Ephedrine Hydrochloric acidc
Ergometrine Methyl ethyl ketone
Ergotamine Piperidine
Isosafrole Sulphuric acidc
Lysergic acid Toluene
3,4-Methylenedioxyphenyl-2-propanone
3,4-MDP-2-P methyl glycidateb
3,4-MDP-2-P methyl glycidic acidb
Norephedrine
N-Phenethyl-4-piperidone (NPP)a
Phenylacetic acid
alpha-Phenylacetoacetamide (APAA)b
alpha-Phenylacetoacetonitrile (APAAN)
1-Phenyl-2-propanone
Piperonal
Potassium permanganate
Pseudoephedrine
Safrole

The salts of the substances listed in this Table, whenever The salts of the substances listed in this Table, whenever
the existence of such salts is possible. the existence of such salts is possible.

a
Included in Table I, effective 18 October 2017.
b
Included in Table I, effective 19 November 2019.
c
The salts of hydrochloric acid and sulphuric acid are specifically excluded from Table II.
102   INCB REPORT ON PRECURSORS 2019

Annex VIII

Use of scheduled substances in the illicit manufacture

of narcotic drugs and psychotropic substances
Figures I–V below depict the use of scheduled substances in the illicit manufacture of narcotic drugs and p
­ sychotropic
substances. The approximate quantities provided are based on common manufacturing methods. Other manufacturing
methods using scheduled substances – or even non-scheduled substances instead of or in addition to scheduled ­substances
– may also be encountered, depending on the geographical location.

Figure I. Illicit manufacture of cocaine and heroin: scheduled substances and the approximate quantities
thereof required for the illicit manufacture of 100 kilograms of cocaine or heroin hydrochloride

Coca leaf Opium

Sulphuric acid
(100–300 litres)

Coca base/paste Morphine

Potassium permanganate Acetic anhydride

(20–55 kilograms) (100–250 litres)

Cocaine Heroin

Acetone/ethyl ether/methyl
ethyl ketone/toluene Acetone/ethyl ether
(1,000-2,000 litres) (10–100 litres)
Hydrochloric acid Hydrochloric acid
(20–40 litres) (30–40 litres)

Cocaine hydrochloride Heroin hydrochloride

(100 kilograms) (100 kilograms)

Note: The extraction of cocaine from coca leaf and the purification of coca paste and the crude base products of
cocaine and heroin require solvents, acids and bases. A wide range of such chemicals are used at all stages of drug
manufacture.
 Annex VIII  103

Figure II. Illicit manufacture of amphetamine and methamphetamine: scheduled substances and the
approximate quantities thereof required for the illicit manufacture of 100 kilograms of amphetamine
­sulphate and methamphetamine hydrochloride

alpha- alpha-
Phenylacetic acid
Phenylacetoacetamide Phenylacetoacetonitrile
(120–180 kilograms)
(150–230 kilograms)a (150–230 kilograms)a

Acetic anhydride Sulphuric acid

(180–280 litres)

Norephedrine Pseudo/Ephedrine
1-Phenyl-2-propanoneb
hydrochloride hydrochloride
(100–150 litres)
(130 kilograms) (150 kilograms)

Amphetamine Methamphetamine

Sulphuric acid Hydrochloric acid

Amphetamine sulphate Methamphetamine hydrochloride

(100 kilograms) (100 kilograms)

Note: Methcathinone, a less commonly encountered amphetamine-type stimulant, can be manufactured from
pseudo/ephedrine hydrochloride, requiring the same approximate quantities as methamphetamine to yield 100 kilograms
of hydrochloride salt.

a
The weight range reflects the fact that APAA and APAAN are purpose-made designer precursors without recognized legitimate uses and are
therefore often impure (street-level quality).
b
Methods based on 1-phenyl-2-propanone result in racemic d,l-meth/amphetamine, while methods based on ephedrine, pseudoephedrine or
norephedrine result in d-meth/amphetamine. In a subsequent step, racemic d,l-meth/amphetamine can be – and actually is – separated in illicit labora-
tories to also produce d-meth/amphetamine.
104   INCB REPORT ON PRECURSORS 2019

Figure III. Illicit manufacture of 3,4-methylenedioxymethamphetamine (MDMA) and related drugs:

s­ cheduled substances and the approximate quantities thereof required for the illicit manufacture of
100 kilograms of MDMA

Piperonal Safrole-rich oilsa

(210 kilograms) (210 litres)

3,4-MDP-2-P methyl- Safrole

glycidateb (210 kilograms) Intermediates A
(150 litres)

3,4-MDP-2-P
Intermediates Bc
(110 litres)

3,4-Methylenedioxymethamphetamine (MDMA)
(100 kilograms)

Hydrochloric acid

MDMA hydrochloride

Note: Isosafrole, another precursor of MDMA under international control, is not included in this scheme, as it is
not commonly encountered as a starting material; it is an intermediate in a modification of methods for manufactur-
ing MDMA from safrole, requiring approximately 300 litres of safrole to manufacture 100 kilograms of MDMA.

a
Assuming the safrole-rich oils have a safrole content of 75 per cent or higher.
b
Refers, for the purpose of this scheme, to the methyl ester and salts of 3,4-MDP-2-P methyl glycidic acid (i.e., purpose-made designer precursors
without recognized legitimate uses that are therefore often impure (street-level quality)).
c
The manufacture of 100 kilograms of MDMA via intermediates B would require 200 litres of safrole.
 Annex VIII  105

Figure IV. Illicit manufacture of methaqualone and phencyclidine: scheduled substances and the
­approximate quantities thereof required for the illicit manufacture of 100 kilograms of methaqualone
and phencyclidine

Anthranilic acid
(100 kilograms)

Acetic anhydride
(100 litres)

Piperidine N-Acetylanthranilic acid

(80 litres) (125 kilograms)

Hydrochloric
acid

Phencyclidine Methaqualone
(100 kilograms) (100 kilograms)

Figure V. Illicit manufacture of lysergic acid diethylamide (LSD) and fentanyl: scheduled substances and
the approximate quantities thereof required for the illicit manufacture of 1 kilogram of LSD or fentanyl

Ergometrine Ergotamine N-Phenethyl-4-

(3 kilograms) (5 kilograms) piperidone (NPP)
(1.5 kilograms)

Lysergic acid
(1.5 kilograms)
4-Anilino-N-phenethyl-
4-piperidine (ANPP)
(1.3 kilograms)

LSD
(1 kilogram)
Fentanyl
(1 kilogram)
106   INCB REPORT ON PRECURSORS 2019

Annex IX

Licit uses of the substances in Tables I and II of the

United Nations Convention against Illicit Traffic in
Narcotic Drugs and Psychotropic Substances of 1988
Knowledge of the most common licit uses of substances in Tables I and II of the United Nations Convention against
Illicit Traffic in Narcotic Drugs and Psychotropic Substances of 1988, including the processes and end products in which
the substances may be used, is essential for the verification of the legitimacy of orders or shipments. The most common
licit uses of those substances reported to the International Narcotics Control Board are as follows:

Substance Licit uses

Acetic anhydride Acetylating and dehydrating agent used in the chemical and
­pharmaceutical industries for the manufacture of cellulose acetate, for
textile sizing agents and cold bleaching activators, for polishing metals
and for the production of brake fluids, dyes and explosives
Acetone As a common solvent and intermediate for a variety of substances in
the chemical and pharmaceutical industries, including plastics, paints,
lubricants, varnishes and cosmetics; also used in the manufacture of
other solvents, such as chloroform
N-Acetylanthranilic acid Used in the manufacture of pharmaceuticals, plastics and fine
chemicals
4-Anilino-N-phenethylpiperidine (ANPP) Used in the pharmaceutical industry for the manufacture of fentanyl
Anthranilic acid Chemical intermediate used in the manufacture of dyes,
­pharmaceuticals and perfumes; also used in the preparation of bird
and insect repellents
Ephedrine Used in the manufacture of bronchodilators (cough medicines)
Ergometrine Used in the treatment of migraine and as an oxytocic in obstetrics
Ergotamine Used in the treatment of migraine and as an oxytocic in obstetrics
Ethyl ether Commonly used solvent in chemical laboratories and in the chemical
and pharmaceutical industries; mainly used as an extractant for fats,
oils, waxes and resins; also used for the manufacture of munitions,
plastics and perfumes and, in medicine, as a general anaesthetic
Hydrochloric acid Used in the production of chlorides and hydrochlorides, for the
neutralization of basic systems and as a catalyst and solvent in
organic synthesis
Isosafrole Used in the manufacture of piperonal; to modify “oriental perfumes”;
to strengthen soap perfumes; in small quantities, together with methyl
salicylate, in root beer and sarsaparilla flavours; and as a pesticide
Lysergic acid Used in organic synthesis
3,4-Methylenedioxyphenyl-2-propanone Used in the manufacture of piperonal and other perfume components
3,4-MDP-2-P methyl glycidate None, except — in small amounts — for research, development and
laboratory analytical purposes
3,4-MDP-2-P methyl glycidic acid None, except — in small amounts — for research, development and
laboratory analytical purposes
Methyl ethyl ketone Common solvent; used in the manufacture of coatings, solvents,
degreasing agents, lacquers, resins and smokeless powders
Norephedrine Used in the manufacture of nasal decongestants and appetite
suppressants
 Annex IX  107

Substance Licit uses

N-Phenethyl-4-piperidone (NPP) Used in the pharmaceutical industry, mainly for the manufacture of
fentanyl and carfentanil
Phenylacetic acid Used in the chemical and pharmaceutical industries for the manufac-
ture of phenylacetate esters, amphetamine and some derivatives; also
used for the synthesis of penicillins and in fragrance applications and
cleaning solutions
alpha-Phenyl-acetoacetamide (APAA) None, except — in small amounts — for research, development and
laboratory analytical purposes
alpha-Phenyl-acetoacetonitrile (APAAN) None, except — in small amounts — for research, development and
laboratory analytical purposes
1-Phenyl-2-propanone Used in the chemical and pharmaceutical industries for the manufac-
ture of amphetamine, methamphetamine and some derivatives; also
used for the synthesis of propylhexedrine
Piperidine Commonly used solvent and reagent in chemical laboratories and in
the chemical and pharmaceutical industries; also used in the manufac-
ture of rubber products and plastics
Piperonal Used in perfumery, in cherry and vanilla flavours, in organic synthesis
and as a component for mosquito repellent
Potassium permanganate Important reagent in analytical and synthetic organic chemistry; used
in bleaching applications, disinfectants, antibacterials and antifungal
agents and in water purification
Pseudoephedrine Used in the manufacture of bronchodilators and nasal decongestants
Safrole Used in perfumery, for example in the manufacture of piperonal, and
for denaturing fats in soap manufacture
Sulphuric acid Used in the production of sulphates; as an acidic oxidizer; as a
dehydrating and purifying agent; for the neutralization of alkaline
solutions; as a catalyst in organic synthesis; in the manufacture of
fertilizers, explosives, dyestuffs and paper; and as a component of
drain and metal cleaners, anti-rust compounds and automobile battery
fluids
Toluene Industrial solvent; used in the manufacture of explosives, dyes,
coatings and other organic substances and as a gasoline additive
108   INCB REPORT ON PRECURSORS 2019

Annex X

Treaty provisions for the control of substances

­frequently used in the illicit manufacture of narcotic
drugs and psychotropic substances
1. Article 2, paragraph 8, of the Single Convention on Narcotic Drugs of 1961 as amended by the 1972 Protocol p ­ rovides
that parties shall use their best endeavours to apply to substances which do not fall under the Convention, but which may
be used in the illicit manufacture of drugs, such measures of supervision as may be practicable.

2. Article 2, paragraph 9, of the Convention on Psychotropic Substances of 1971 provides that parties shall use their
best endeavours to apply to substances which do not fall under the Convention, but which may be used in the illicit
manufacture of psychotropic substances, such measures of supervision as may be practicable.

3. Article 12 of the United Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances of
1988 contains provisions for the following:
(a) General obligation for parties to take measures to prevent diversion of the substances in Tables I and II of the
Convention and to cooperate with each other to that end (para. 1);
(b) Mechanism for amending the scope of control (paras. 2–7);
(c) Requirement to take appropriate measures to monitor manufacture and distribution, to which end parties may
control persons and enterprises, control establishments and premises under licence, require permits for manufacture or
distribution of substances in Tables I and II and prevent accumulation of such substances (para. 8);
(d) Obligation to monitor international trade in order to identify suspicious transactions, to provide for seizures, to
notify the authorities of the parties concerned in case of suspicious transactions, to require proper labelling and
­documentation and to ensure maintenance of such documents for at least two years (para. 9);
(e) Mechanism for advance notice of exports of substances in Table I, upon request (para. 10);
(f) Confidentiality of information (para. 11);
(g) Reporting by parties to the International Narcotics Control Board (para. 12);
(h) Report of the Board to the Commission on Narcotic Drugs (para. 13);
(i) Non-applicability of the provisions of article 12 to certain preparations (para. 14).
 Annex XI  109

Annex XI

Regional groupings
Reference is made throughout the present report to various geographical regions, which are defined as follows:
Africa: Algeria, Angola, Benin, Botswana, Burkina Faso, Burundi, Cabo Verde, Cameroon, Central African Republic,
Chad, Comoros, Congo, Côte d’Ivoire, Democratic Republic of the Congo, Djibouti, Egypt, Equatorial Guinea, Eritrea,
Eswatini,a Ethiopia, Gabon, Gambia, Ghana, Guinea, Guinea-Bissau, Kenya, Lesotho, Liberia, Libya, Madagascar, Malawi,
Mali, Mauritania, Mauritius, Morocco, Mozambique, Namibia, Niger, Nigeria, Rwanda, Sao Tome and Principe, Senegal,
Seychelles, Sierra Leone, Somalia, South Africa, South Sudan, Sudan, Togo, Tunisia, Uganda, United Republic of Tanzania,
Zambia and Zimbabwe;
Central America and the Caribbean: Antigua and Barbuda, Bahamas, Barbados, Belize, Costa Rica, Cuba, Dominica,
Dominican Republic, El Salvador, Grenada, Guatemala, Haiti, Honduras, Jamaica, Nicaragua, Panama, Saint Kitts and
Nevis, Saint Lucia, Saint Vincent and the Grenadines, and Trinidad and Tobago;
North America: Canada, Mexico and United States of America;
South America: Argentina, Bolivia (Plurinational State of), Brazil, Chile, Colombia, Ecuador, Guyana, Paraguay, Peru,
Suriname, Uruguay and Venezuela (Bolivarian Republic of);
East and South-East Asia: Brunei Darussalam, Cambodia, China, Democratic People’s Republic of Korea, Indonesia,
Japan, Lao People’s Democratic Republic, Malaysia, Mongolia, Myanmar, Philippines, Republic of Korea, Singapore,
Thailand, Timor-Leste and Viet Nam;
South Asia: Bangladesh, Bhutan, India, Maldives, Nepal and Sri Lanka;
West Asia: Afghanistan, Armenia, Azerbaijan, Bahrain, Georgia, Iran (Islamic Republic of), Iraq, Israel, Jordan,
Kazakhstan, Kuwait, Kyrgyzstan, Lebanon, Oman, Pakistan, Qatar, Saudi Arabia, State of Palestine, Syrian Arab Republic,
Tajikistan, Turkey, Turkmenistan, United Arab Emirates, Uzbekistan and Yemen;
Europe:
Eastern Europe: Belarus, Republic of Moldova, Russian Federation and Ukraine;
South-Eastern Europe: Albania, Bosnia and Herzegovina, Bulgaria, Croatia, Montenegro, North Macedonia,b

Romania and Serbia;
Western and Central Europe: Andorra, Austria, Belgium, Cyprus, Czechia,c Denmark, Estonia, Finland, France,

Germany, Greece, Holy See, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta,
Monaco, Netherlands, Norway, Poland, Portugal, San Marino, Slovakia, Slovenia, Spain, Sweden, Switzerland and
United Kingdom of Great Britain and Northern Ireland;
Oceania: Australia, Cook Islands, Fiji, Kiribati, Marshall Islands, Micronesia (Federated States of), Nauru, New Zealand,
Niue, Palau, Papua New Guinea, Samoa, Solomon Islands, Tonga, Tuvalu and Vanuatu.

a
Since 19 April 2018, “Eswatini” has replaced “Swaziland” as the short name used in the United Nations.
b
Since 14 February 2019, “North Macedonia” has replaced “the former Yugoslav Republic of Macedonia” as the short name used in the United Nations.
c
Since 17 May 2016, “Czechia” has replaced “Czech Republic” as the short name used in the United Nations.
About the International Narcotics Control Board
The International Narcotics Control Board (INCB) is an diversion of drugs from licit sources to illicit channels does
independent and quasi-judicial control organ, established by not occur. INCB also monitors Governments’ control over
treaty, for monitoring the implementation of the inter- chemicals used in the illicit manufacture of drugs and assists
national drug control treaties. It had predecessors under the them in preventing the diversion of those chemicals into the
former drug control treaties as far back as the time of the illicit traffic;
League of Nations.
(b) As regards the illicit manufacture of, trafficking in
and use of drugs, INCB identifies weaknesses in national and
Composition international control systems and contributes to correcting
such situations. INCB is also responsible for assessing chemi-
INCB consists of 13 members who are elected by the
cals used in the illicit manufacture of drugs, in order to
Economic and Social Council and who serve in their per-
determine whether they should be placed under international
sonal capacity, not as government representatives. Three
control.
members with medical, pharmacological or pharmaceutical
experience are elected from a list of persons nominated by
In the discharge of its responsibilities, INCB:
the World Health Organization (WHO) and 10 members are
elected from a list of persons nominated by Governments.
(a) Administers a system of estimates for narcotic
Members of the Board are persons who, by their competence,
drugs and a voluntary assessment system for psychotropic
impartiality and disinterestedness, command general confi-
substances and monitors licit activities involving drugs
dence. The Council, in consultation with INCB, makes all
through a statistical returns system, with a view to assisting
arrangements necessary to ensure the full technical inde-
Governments in achieving, inter alia, a balance between
pendence of the Board in carrying out its functions. INCB
supply and demand;
has a secretariat that assists it in the exercise of its treaty-
related functions. The INCB secretariat is an administrative
(b) Monitors and promotes measures taken by
entity of the United Nations Office on Drugs and Crime, but
Governments to prevent the diversion of substances fre-
it reports solely to the Board on matters of substance. INCB
quently used in the illicit manufacture of narcotic drugs and
closely collaborates with the Office in the framework of
psychotropic substances and assesses such substances to
arrangements approved by the Council in its resolution
determine whether there is a need for changes in the scope of
1991/48. INCB also cooperates with other international
control of Tables I and II of the 1988 Convention;
bodies concerned with drug control, including not only the
Council and its Commission on Narcotic Drugs, but also the
(c) Analyses information provided by Governments,
relevant specialized agencies of the United Nations, particu-
United Nations bodies, specialized agencies or other compe-
larly WHO. It also cooperates with bodies outside the United
tent international organizations, with a view to ensuring that
Nations system, especially the International Criminal Police
the provisions of the international drug control treaties are
Organization (INTERPOL) and the World Customs
adequately carried out by Governments, and recommends
Organization.
remedial measures;

(d) Maintains a permanent dialogue with Governments

Functions
to assist them in complying with their obligations under the
The functions of INCB are laid down in the following trea- international drug control treaties and, to that end, recom-
ties: Single Convention on Narcotic Drugs of 1961 as mends, where appropriate, technical or financial assistance
amended by the 1972 Protocol; Convention on Psychotropic to be provided.
Substances of 1971; and United Nations Convention against
Illicit Traffic in Narcotic Drugs and Psychotropic Substances INCB is called upon to ask for explanations in the event of
of 1988. Broadly speaking, INCB deals with the following: apparent violations of the treaties, to propose appropriate
remedial measures to Governments that are not fully apply-
(a) As regards the licit manufacture of, trade in and use ing the provisions of the treaties or are encountering difficul-
of drugs, INCB endeavours, in cooperation with ties in applying them and, where necessary, to assist
Governments, to ensure that adequate supplies of drugs are Governments in overcoming such difficulties. If, however,
available for medical and scientific uses and that the INCB notes that the measures necessary to remedy a serious
situation have not been taken, it may call the matter to the recommendations for improvements at both the national
attention of the parties concerned, the Commission on and international levels. The annual report is based on infor-
Narcotic Drugs and the Economic and Social Council. As a mation provided by Governments to INCB, United Nations
last resort, the treaties empower INCB to recommend to par- entities and other organizations. It also uses information
ties that they stop importing drugs from a defaulting coun- provided through other international organizations, such as
try, exporting drugs to it or both. In all cases, INCB acts in INTERPOL and the World Customs Organization, as well as
close cooperation with Governments. regional organizations.

INCB assists national administrations in meeting their obli- The annual report of INCB is supplemented by detailed tech-
gations under the conventions. To that end, it proposes and nical reports. They contain data on the licit movement of
participates in regional training seminars and programmes narcotic drugs and psychotropic substances required for
for drug control administrators. medical and scientific purposes, together with an analysis of
those data by INCB. Those data are required for the proper
functioning of the system of control over the licit movement
Reports
of narcotic drugs and psychotropic substances, including
The international drug control treaties require INCB to pre- preventing their diversion to illicit channels. Moreover,
pare an annual report on its work. The annual report con- under the provisions of article 12 of the 1988 Convention,
tains an analysis of the drug control situation worldwide so INCB reports annually to the Commission on Narcotic
that Governments are kept aware of existing and potential Drugs on the implementation of that article. That report,
situations that may endanger the objectives of the inter- which gives an account of the results of the monitoring of
national drug control treaties. INCB draws the attention of precursors and of the chemicals frequently used in the illicit
Governments to gaps and weaknesses in national control manufacture of narcotic drugs and psychotropic substances,
and in treaty compliance; it also makes suggestions and is also published as a supplement to the annual report.
*1911146*
 INTERNATIONAL NARCOTICS CONTROL BOARD

The International Narcotics Control Board (INCB) is the independent monitoring body for the
implementation of United Nations international drug control conventions. It was established
in 1968 in accordance with the Single Convention on Narcotic Drugs, 1961. It had predecessors
under the former drug control treaties as far back as the time of the League of Nations.
Based on its activities, INCB publishes an annual report that is submitted to the United Nations
Economic and Social Council through the Commission on Narcotic Drugs. The report provides
a comprehensive survey of the drug control situation in various parts of the world. As an
impartial body, INCB tries to identify and predict dangerous trends and suggests necessary
measures to be taken.

ISBN 978-92-1-148339-0
V.19-11146