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China Primer: Illicit Fentanyl and China's Role


For over a decade, the synthetic opioid fentanyl and
fentanyl-related substances have been key drivers of the
U.S. opioid crisis. Countering the illicit trafficking of
fentanyl and the precursor chemicals (precursors) used to
make  it has been a U.S. priority. In 2015, the Drug
Enforcement Administration (DEA)  first identified the
People's Republic of China (PRC, or China) as the main
source of U.S.-bound fentanyl and fentanyl precursors.
Since the PRC imposed domestic controls on fentanyl-
related substances in 2019, which curtailed almost all direct
shipments of fentanyl from China to the United States,
many  U.S. policymakers have shifted focus. Their chief
concern today is the role of China-the global leader in
chemical sales-as the primary source of precursors used
by transnational criminal organizations (TCOs) to
synthesize fentanyl and its analogues in third countries
(chiefly Mexico). Congress has sought to address China's
shifting role in the illicit drug trade, including through
provisions in the BUST Fentanyl Act in the National
Defense Authorization Act for FY2026.

  ackground
Fentanyl is a potent synthetic opioid that has been used
medically as a painkiller and an anesthetic since it was first
synthesized in 1959. Due to fentanyl's potential for abuse
and addiction, the United Nations (UN) placed it under
international control in 1964. Domestically, fentanyl is
regulated by the DEA, pursuant to the Comprehensive Drug
Abuse Prevention and Control Act of 1970, as amended (21
U.S.C. §§801 et seq.). The U.S. Centers for Disease Control
and Prevention estimate that synthetic opioids (primarily
fentanyl-related substances) resulted in about 48,422 U.S.
overdose deaths in 2024-a decrease of 36.5% from 76,282
in 2023.
As of January 2026, the International Narcotics Control
Board (INCB)-an   independent expert body that monitors
governments' compliance with UN  drug control
conventions-reported  the existence of 153 fentanyl-related
substances with no known legitimate use. The UN Office
on Drugs and Crime estimates that laboratories could
potentially synthesize thousands of fentanyl-related
substances. More than 30 fentanyl-related substances,
including precursors, are controlled (scheduled)
internationally pursuant to the UN Single Convention on
Narcotic Drugs of 1961, as amended, and the UN
Convention Against Illicit Traffic in Narcotic Drugs and
Psychotropic Substances of 1988. UN member states began
scheduling fentanyl precursors for international control in
2017. As of January 2026, the INCB had scheduled seven
fentanyl precursors for international control.
Sources and Traffickin Pathways
According to the DEA, fentanyl sourced from China
accounted for 97% of high-purity fentanyl seized from
shipments to the United States in 2016 and 2017. In 2019,


Updated February 17, 2026


in response to U.S. concerns expressed by the first Trump
Administration, the PRC government controlled fentanyl
substances as a class, leading to a major change in
trafficking patterns. According to the Department of State's
March  2025 International Narcotics Control Strategy
Report (INCSR), almost no fentanyl or fentanyl analogues
have been detected directly entering the United States from
[China] since the PRC implemented controls over fentanyl-
related substances as a class in 2019. (The report notes that
production of U.S.-bound illicit fentanyl and analogues is
now  concentrated in Mexico.)

On the other hand, China is the primary source country for
illicit fentanyl precursor chemicals and pill pressing
equipment, according to the U.S. intelligence community's
March  2025 Annual Threat Assessment. China's massive
chemical and pharmaceutical industries make the PRC a
primary supplier not only of precursors for fentanyl, but
also for illicit drugs including methamphetamine, ketamine,
and nitazenes. Because of the PRC's role as a supplier of
precursors, the President has designated China a major
illicit drug producing or drug transit country since 2023,
following Congress' 2022 amendment  (P.L. 117-263) of the
definition to include synthetic drugs and their precursors.

U.S.   Executve ranch Actions
Successive Administrations have acted to address China's
role in the trafficking of fentanyl and its precursors. The
United States has sanctioned multiple PRC citizens and
PRC-based  companies. Over the past decade, the executive
branch also has indicted dozens of PRC citizens and PRC-
based companies for their alleged involvement in the
trafficking of synthetic drugs, precursor chemicals, and pill-
making  equipment, and related money laundering. In
December  2025, the second Trump Administration, through
Executive Order (E.O.) 14367, designated illicit fentanyl
and its core precursor chemicals as Weapons of Mass
Destruction.

The second Trump  Administration has sought to address
China's role in the U.S. opioid epidemic in part by levying
tariffs on PRC goods. On February 1, 2025, the White
House issued E.O. 14195, which expanded the national
emergency  the President declared in January 2025
(Proclamation 10886) to cover the failure of the PRC
government  to arrest, seize, detain, or otherwise intercept
chemical precursor suppliers, money launderers, other
TCOs,  criminals at large, and drugs, the order
subsequently imposed an additional 10% tariff on PRC
products pursuant to authorities including those under the
International Emergency Economic Powers Act (IEEPA).
In subsequent orders, the President directed duty-free de
minimis treatment to be suspended for low-value imports
from China (premised on the alleged use of such shipments
as an avenue for the trafficking of illicit substances) and the