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Updated January 29, 2021
Illicit Fentanyl and China’s Role
Addressing illicit fentanyl in the context of the ongoing
manufactured fentanyl pharmaceutical products may be
opioid crisis is both a domestic and foreign policy issue for
illicitly diverted through theft and fraudulent prescriptions.
the 117th Congress. According to U.S. estimates, synthetic
opioids, including predominantly foreign-sourced fentanyl
China has been a major source of U.S.-bound fentanyl and,
and fentanyl-related compounds (analogues), killed more
more recently, precursors and production equipment
Americans in the past 12 months than any other type of
(Figure 1). In January 2020, DEA assessed that although
opioid. In addressing the international dimensions of the
China remained the “primary source” of all fentanyl-related
problem, policymakers have faced challenges in stopping
substances trafficked into the United States, other sources
fentanyl, fentanyl-related substances, and emerging
of fentanyl were emerging. Based on U.S. seizure data,
synthetic opioids from entering the United States. In recent
fentanyl and fentanyl analogues were often mailed from
years, counternarcotics attention has focused on reducing
China in parcel packages. These small (typically less than 1
fentanyl flows from China.
kilogram in weight), high-purity (often testing above 90%
purity) parcels would arrive in the United States, Canada,
Background
and Mexico, where they would be mixed with heroin (or
Fentanyl is a potent synthetic opioid that has been used
other illicit drugs, including cocaine and
medically as a painkiller and an anesthetic since it was first
methamphetamine) or pressed into pills (some purporting to
synthesized in 1959. Due to fentanyl’s potential for abuse
be name-brand pharmaceutical opioid preparations). In
and addiction, the United Nations (U.N.) placed it under
December 2020 testimony, the U.S. Postal Service (USPS)
strict international control in 1964. In the United States, it is
reported two consecutive years of “dramatic” declines in
regulated by the Drug Enforcement Administration (DEA),
the number of seizures of suspected fentanyl or synthetic
pursuant to the Comprehensive Drug Abuse Prevention and
opioids in inbound international mail. At the same hearing,
Control Act of 1970, as amended (21 U.S.C. 801 et seq.).
U.S. Customs and Border Protection (CBP) noted that
despite an “apparent shift in fentanyl production to other
In recent years, fentanyl and its analogues have emerged as
countries such as India and Mexico,” China remains a
a major international drug control problem. Overdose
“major source country” for a variety of controlled
deaths from their abuse have continued to rise, and a
substances and drug-related manufacturing equipment,
growing number of fentanyl analogues appear marketed for
including pill presses.
nonmedical, often unregulated use. In September 2020, the
International Narcotics Control Board reported the
Arrangements to procure fentanyl, fentanyl analogues, and
existence of 144 fentanyl-related substances with no
related precursors are typically conducted online. Producers
currently known legitimate uses. The U.N. Office on Drugs
advertise products on the clear web through public
and Crime estimates that laboratories could potentially
websites, social media accounts, and password-protected
synthesize thousands of other fentanyl analogues. As of
marketplaces. Further complicating law enforcement
December 2020, fentanyl and 26 fentanyl analogues are
detection, traffickers often exploit features of the dark web
scheduled for international control pursuant to the U.N.
and cryptocurrencies to procure and purchase fentanyl and
Single Convention on Narcotic Drugs.
fentanyl analogues anonymously.
In 2018, U.N. member states agreed to place two common
Figure 1. China-Sourced Fentanyl Trafficking Flows
chemicals used to produce fentanyl (fentanyl “precursor
chemicals”) under international control: N-phenethyl-4-
piperidone (NPP) and 4-anilino-N-phenethyl-4-piperidone
(ANPP). Since then, traffickers have shifted to producing
other fentanyl precursors, such as 4-AP, which have not
been internationally regulated.
Sources and Trafficking Pathways
While not a new phenomenon, the illicit production and
trafficking of fentanyl and fentanyl analogues in recent
years have been associated with rising numbers of U.S.
opioid-related overdose fatalities, as well as fatalities in
Canada and Europe. Clandestine laboratories may engage in
Source: DEA (2020).
illicit production of fentanyl, fentanyl analogues, and
precursors. Otherwise legitimate companies may produce
Addressing China’s Role
unregulated analogues and precursors. Also, legally
To address the problem of illicit fentanyl from China, the
U.S. government has pressed China to impose domestic
controls on fentanyl analogues and precursors, indicted and
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Illicit Fentanyl and China’s Role
sanctioned Chinese fentanyl manufacturers and distributors,
described that as “a major accomplishment, and likely due
and negotiated for more advance tracking information on
to cooperative efforts over the course of several years.”
packages from China. Even as the overall U.S.-China
relationship has grown more contentious, those efforts and
Some U.S. objectives with respect to China remain unmet.
others appear to have yielded progress.
China has not taken action to control additional fentanyl
precursors, following China’s listing of two fentanyl
In 2019, China imposed domestic controls on the entire
precursors, NPP and 4-ANPP, as controlled substances in
fentanyl class of chemicals, including all known and all
February 2018. According to the 2020 INSCR, after China
potential future variations of fentanyl. It said it did so, in
controlled NPP and 4-ANPP, “Chinese traffickers shifted to
part, “to respond to the U.S. side’s concern.” China first
sending not yet controlled chemicals to Mexico (such as 4-
announced its intention to pursue class scheduling in
AP).” In addition, China has not so far approved DEA
December 2018, following a meeting between then-
requests to open offices in the Chinese cities of Guangzhou
President Donald J. Trump and China’s President Xi
and Shanghai, and Chinese nationals indicted in the United
Jinping on the sidelines of a G-20 meeting in Buenos Aires.
States on fentanyl trafficking charges remain at large.
On May 1, 2019, China added all fentanyl-related
substances not already scheduled to its “Supplementary List
U.S. Foreign Policy Responses
of Controlled Narcotic Drugs and Psychotropic Substances
Targeting the foreign supply of U.S.-destined illicit drugs
with Non-Medical Use.” According to the State
has long been a pillar of U.S. counternarcotics strategy.
Department’s 2020 International Narcotics Control Strategy
Foreign policy approaches to stemming the flow of illicit
Report (INSCR), China’s class scheduling of fentanyl “led
fentanyl into the United States have focused on bilateral
to pronounced shifts in fentanyl and fentanyl analogue
engagement, including with China, and multilateral
flows to the United States.” The INSCR cited CBP data
cooperation with the United Nations and other stakeholders
showing seizures of fentanyl directly shipped from China
on such goals as scheduling more fentanyl analogues and
dropped from over 116 kilograms in FY2017 to less than
precursors for international drug control. Today’s synthetic
200 grams in FY2019.
opioid problem poses particular challenges for the current
counternarcotics policy toolbox, including the rapid pace at
Justice and Treasury Departments efforts may have
which new designer analogues and precursor chemicals
increased pressure on Chinese fentanyl traffickers. In
appear, as well as the emergence of newer trafficking
October 2017, the Justice Department announced that it had
networks and online marketing and payment methods.
designated two Chinese nationals, Yan Xiaobing and Zhang
Jian, as Consolidated Priority Organization Targets
The 116th Congress saw multiple bills seeking to address
(CPOTs), making them the first fentanyl manufacturers and
fentanyl and opioid-related concerns in the context of
distributors of any nationality to be so designated. The term
public health, domestic border security, law enforcement,
refers to “‘command and control’ elements of the most
and postal service controls, as well as foreign policy.
prolific international drug trafficking and money laundering
Incorporated into the National Defense Authorization Act
organizations.” In April 2018, the Treasury Department
for FY2020 (P.L. 116-92), the Fentanyl Sanctions Act
designated Zhang as a significant foreign narcotic trafficker
enhanced the President’s ability to impose sanctions on
pursuant to the Foreign Narcotics Kingpin Designation Act
synthetic opioids traffickers based in China and other
(P.L. 106-120), the first time the department designated an
foreign countries. The Temporary Reauthorization and
accused fentanyl trafficker of any nationality under the act.
Study of the Emergency Scheduling of Fentanyl Analogues
The Treasury Department later identified three more
Act (P.L. 116-114) requires the U.S. Government
Chinese nationals—Yan Xiaobing, Zheng Fujing, and
Accountability Office (GAO) to study and report on the
Zhang Taotao—and Zheng’s drug trafficking organizations
impacts of class-wide scheduling of fentanyl-related
as significant foreign narcotics traffickers pursuant to the
substances, including the impact controls on China’s supply
act. All are accused of fentanyl trafficking. The U.S.
of fentanyl substances to the United States.
government has also teamed up with Chinese officials to
jointly investigate fentanyl traffickers. In November 2019, a
Congressional Outlook
joint U.S.-China investigation resulted in a Chinese court
As the 117th Congress considers policy options to address
sentencing nine defendants for trafficking fentanyl to the
fentanyl flows from China, issues may include the effects of
United States. The investigation originated with a 2017 tip
the Coronavirus Disease 2019 (COVID-19) pandemic on
from the U.S. Department of Homeland Security.
trafficking flows and bilateral cooperation; the effectiveness
of the Fentanyl Sanctions Act; and whether additional
Intelligence sharing may have helped curb fentanyl flows.
foreign policy tools, including bilateral and multilateral
According to CBP in December 2020 testimony, the agency
information sharing, are needed to address emerging trends
now “regularly shares targeting information” with China’s
in synthetic opioid production and trafficking.
Ministry of Public Security and the General Administration
of China Customs. In addition, pursuant to a bilateral
Liana W. Rosen, Specialist in International Crime and
agreement, China’s postal service, China Post, provides
Narcotics
USPS with advanced electronic data (AED) on parcels
Susan V. Lawrence, Specialist in Asian Affairs
mailed to the United States. The data help CBP target high-
risk shipments for inspection. In testimony at the same
IF10890
December 2020 hearing, USPS stated that China Post was
“nearly fully achieving the prescribed level of AED.” USPS
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Illicit Fentanyl and China’s Role
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https://crsreports.congress.gov | IF10890 · VERSION 6 · UPDATED