Updated February 13, 2024
China Primer: Illicit Fentanyl and China’s Role
In the context of the ongoing opioid crisis in the United
N-Phenethyl-4-piperidone (NPP) and 4-Anilino-N-
States, illicit fentanyl is both a domestic and a foreign
phenethylpiperidine (ANPP) on Table I of the 1988
policy issue for Congress. In addressing the international
Convention. In 2018, consistent with the U.N. decision, the
dimension, policymakers have endeavored to stop foreign-
PRC implemented corresponding domestic controls. In
sourced fentanyl, fentanyl-related substances (i.e.,
2022, U.N. member states subjected three additional
analogues), and chemical inputs (i.e., precursors) from
fentanyl precursors to international control: N-Phenyl-4-
entering the United States. Early in the rise of U.S. illicit
piperidinamine (4-AP), tert-Butyl 4-(phenylamino)
fentanyl use, beginning in the mid-2010s, U.S. authorities
piperidine-1-carboxylate (boc-4-AP), and norfentanyl. In
identified the People’s Republic of China (PRC, or China)
June 2023, the PRC government said it was “in the process
as the primary source of illicit fentanyl entering the United
of scheduling” three additional fentanyl precursors—
States. Since 2019, direct flows appear to have largely
presumably those the U.N. scheduled in 2022—but the PRC
ceased. The focus of U.S. counternarcotics policy with
has provided no further information.
regard to China has shifted to preventing PRC-sourced
fentanyl precursors, along with manufactured or synthetic
Sources and Trafficking Pathways
drugs often mixed with fentanyl substances, from entering
Prior to 2019, the DEA identified China as the primary
the U.S.-bound fentanyl supply chain. The U.S. government
source of U.S.-bound illicit fentanyl, fentanyl-related
also seeks to prevent illicit exports of pill presses from the
substances, and production equipment. PRC traffickers
PRC and illicit fentanyl-related financial flows linked to
supplied fentanyl and fentanyl-related substances directly to
China. A November 2023 summit in California between
the United States via international mail or express
President Joseph R. Biden, Jr. and China’s leader, Xi
consignment operations.
Jinping, renewed cooperation on drug control issues after
more than three years of stasis.
Trafficking patterns changed after the PRC imposed class-
wide controls over all fentanyl-related substances in 2019.
Background
Today, DEA alleges that PRC-based chemical companies
Fentanyl is a potent synthetic opioid that has been used
advertise and sell online fentanyl precursor chemicals,
medically as a painkiller and an anesthetic since it was first
including some that are not internationally controlled and
synthesized in 1959. Due to fentanyl’s potential for abuse
are correspondingly legal to export out of China, as well as
and addiction, the United Nations (U.N.) placed it under
manufactured or synthetic drugs such as xylazine and
international control in 1964. Domestically, fentanyl is
nitazenes. The companies ship the items to Mexico and
regulated by the Drug Enforcement Administration (DEA),
directly to the United States, including via the U.S. Postal
pursuant to the Comprehensive Drug Abuse Prevention and
Service and express consignment services, “carefully
Control Act of 1970, as amended (21 U.S.C. §§801 et seq.).
packaged to deceive customs inspectors.” According to
The U.S. Centers for Disease Control and Prevention
DEA, customers, often associated with Mexico-based
estimate that synthetic opioids (primarily fentanyl-related
transnational criminal organizations (TCOs), commonly
substances) may have resulted in more than 78,000 U.S.
pay for the chemicals and drugs in cryptocurrencies,
overdose deaths between September 2022 and August 2023.
making it harder for DEA “to follow the money.” They also
Traffickers appear to be marketing a growing number of
pay using U.S. and PRC payment services or bank transfers.
fentanyl analogues for nonmedical, often unregulated, use.
DEA alleges that the TCOs use largely PRC-sourced
chemicals to synthesize fentanyl substances in clandestine
As of November 2023, the International Narcotics Control
laboratories, and often mix xylazine and nitazenes into the
Board (INCB)—an independent expert body that monitors
fentanyl substances, making the substances “even deadlier,”
governments’ compliance with U.N. drug control
before distributing them across North America.
conventions—reported the existence of 153 fentanyl-related
substances with no currently-known legitimate uses. The
The 2022 report of the U.S. Commission on Combating
U.N. Office on Drugs and Crime estimates that laboratories
Synthetic Opioid Trafficking (established pursuant to §7221
could potentially synthesize thousands of other fentanyl
of P.L. 116-92) concluded that the PRC’s chemical and
analogues. As of May 2023, more than 30 fentanyl-related
pharmaceutical sectors have “outpaced the government’s
substances, including precursors, are subject to international
efforts to regulate them, creating opportunities for
control (“scheduled”) pursuant to the U.N. Single
unscrupulous vendors to export chemicals needed in their
Convention on Narcotic Drugs of 1961, as amended, and
illegal manufacture.” The U.S. Department of the Treasury
the U.N. Convention Against Illicit Traffic in Narcotic
assesses that Mexico-based cartels are increasingly working
Drugs and Psychotropic Substances of 1988.
with PRC money laundering organizations.
U.N. member states first subjected fentanyl precursors to
international control in 2017, agreeing to list the precursors
https://crsreports.congress.gov

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China Primer: Illicit Fentanyl and China’s Role
Addressing China’s Role
abuses” in the PRC’s Xinjiang Uyghur Autonomous
The Biden Administration’s 2022 National Drug Control
Region. The PRC formally suspended bilateral
Strategy prioritizes increased collaboration with the PRC
counternarcotics cooperation in August 2022, in response to
“on shared drug priorities” and continued engagement “to
then-House Speaker Nancy Pelosi’s visit to Taiwan.
reduce diversion of uncontrolled precursor chemicals.” In
February 2023 Senate testimony, Assistant Secretary of
At their November 2023 summit, President Biden and
State for International Narcotics and Law Enforcement
Communist Party of China General Secretary Xi agreed to
Affairs Todd Robinson noted that the United States has
resume counternarcotics cooperation and to launch a
“encouraged the PRC to improve information-sharing on
counternarcotics working group. In parallel, DOC removed
global chemical flows, strengthen enforcement of customs
the MPS institute from the Entity List. The White House
manifesting agreements, and implement know-your-
reported that the PRC shut down some PRC-based suppliers
customer standards to restrict the sale of precursor
of synthetic drugs and precursors and blocked their
chemicals to only customers with legitimate needs.” In July
international payment accounts. It said the PRC also
2023, the United States launched a Global Coalition to
resumed communications through the INCB to share real-
Address Synthetic Drug Threats, including fentanyl.
time incidents of suspicious shipments of fentanyl-related
substances and other new psychoactive substances, after a
The U.S. government has taken several unilateral actions to
pause of three years. After the summit, the PRC National
address China’s role in fentanyl and precursor trafficking.
Narcotics Control Commission (NNCC), housed within
MPS, warned PRC actors that they may be subject to law
• The U.S. Department of the Treasury’s Office of
enforcement actions from other countries for sales and
Foreign Assets Control has so far sanctioned more than
trafficking of substances not currently subject to controls in
65 mainland China- or Hong Kong-based persons for
China. The warning notice specifically cautioned PRC
illicit fentanyl, xylazine, or nitazenes trafficking. The
actors about sales to the United States and Mexico,
sanctions block assets under U.S. jurisdiction, prohibit
including sales of pill presses. An appendix identified all 51
U.S. persons from engaging in financial transactions
U.S.-listed precursors. In January 2024, U.S. National
with those designated, and ban such traffickers from
Security Advisor Jake Sullivan reported “reductions in
entry into the United States.
precursor chemicals seized at some U.S. airports,
originating from China” since the warning. Sullivan noted,
• In June 2023, the Department of Justice (DOJ) indicted
however, that bilateral cooperation “really needs to be
three PRC-based companies and their employees for
continuous and ongoing. It’s not just one snapshot in time.”
fentanyl-related crimes. In September 2023, DOJ
indicted eight more PRC chemical companies and 12 of
The working group met for the first time in Beijing on
their executives for crimes related to fentanyl, other
January 30, 2024. White House Deputy Homeland Security
synthetic opioids, methamphetamines, and their
Advisor Jen Daskal led the U.S. delegation. Her counterpart
precursor chemicals.
was PRC State Councilor Wang Xiaohong, who serves
concurrently as Minister of Public Security and head of the
• In September 2023, President Biden added China to the
NNCC. A White House readout stated, “The two sides
U.S. list of the world’s major illicit drug-producing and
emphasized the need to coordinate on law enforcement
drug-transit countries, citing the PRC’s role in the
actions; address the misuse of precursor chemicals, pill
production of fentanyl precursors.
presses, and related equipment to manufacture illicit drugs;
target the illicit financing of transnational criminal
U.S.-PRC cooperation on fentanyl has yielded some
organization networks; and engage in multilateral fora.”
successes. In May 2019, the PRC added all fentanyl-related
substances not already scheduled to its “Supplementary List
Related Legislation in the 118th Congress
of Controlled Narcotic Drugs and Psychotropic Substances
The National Defense Authorization Act for FY2024 (P.L.
with Non-Medical Use.” In 2019 and 2021, joint U.S.-
118-31), requires a determination of if the PRC government
China investigations resulted in PRC courts sentencing
“assisted in or approved of the transportation of pill presses,
defendants for trafficking fentanyl to the United States and
fentanyl products, or fentanyl precursors to one or more
Canada. In 2020, the U.S. Postal Service reported that
Mexican drug cartels” (Sec. 1311). It also states that it is
China Post was “nearly fully achieving” the requirement,
the sense of Congress that PRC and Mexican organizations
pursuant to the Synthetics Trafficking and Overdose
that traffic or finance trafficking in illicit fentanyl should be
Prevention (STOP) Act of 2018 (Title VIII, Subtitle A of
“among the highest priorities” for the Office of the Director
P.L. 115-271), that 100% of its U.S.-destination packages
of National Intelligence (Sec. 7325). Pending legislation
be accompanied by customs advance electronic data (AED).
includes the House- and Senate-passed FEND Off Fentanyl
Act (H.R. 815), the House-passed Stop Chinese Fentanyl
Bilateral counternarcotics cooperation appeared to stall
Act of 2023 (H.R. 3203), the Strengthening Sanctions on
beginning in 2020. The PRC government blamed U.S.
Fentanyl Traffickers Act of 2023 (S. 2059), the Stop
actions unrelated to counternarcotics. It pointed to the U.S.
Fentanyl Money Laundering Act of 2023 (H.R. 3244) and
Department of Commerce (DOC)’s June 2020 addition to
the Project Precursor Act (H.R. 3205). Pending Department
its Entity List of an institute under the PRC’s Ministry of
of State, Foreign Operations, and Related Programs
Public Security (MPS), the Institute of Forensic Science,
Appropriations Acts for 2024 (H.R. 4665 and S. 2438)
which subjected the institute to export controls. DOC
would also include fentanyl-related provisions.
alleged the institute was “implicated in human rights
https://crsreports.congress.gov

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China Primer: Illicit Fentanyl and China’s Role

Liana W. Rosen, Specialist in International Crime and
Narcotics
Ricardo Barrios, Analyst in Asian Affairs
IF10890
Susan V. Lawrence, Specialist in Asian Affairs


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https://crsreports.congress.gov | IF10890 · VERSION 14 · UPDATED

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