Statements by Prof. Jallal Toufiq, President,
International Narcotics Control Board (INCB)
Sixty-seventh session of the Commission on Narcotic Drugs
Item 5(a): Changes in the scope of control of substances
Vienna, 19 March 2024
INCB Statement 1: 4-Piperidone and 1-boc-4-piperidone
Mr. Chair, Excellencies, ladies and gentlemen,
1) The International Narcotics Control Board has the responsibility under article 12 of the 1988 Convention to assess chemicals used in the illicit manufacture of drugs in order to determine whether they should be placed under international control.
2) In the discharge of its functions under article 12 of the 1988 Convention, the Board submitted to the Chair of the Commission a recommendation to place two precursors of fentanyl and a number of fentanyl analogues in Table I of that Convention
3) Because of the similarities, I will cover the two chemicals together in one statement.
- The first chemical is 4-Piperidone, an early-stage precursor involved in most synthetic routes to fentanyl and some fentanyl analogues. Specifically, it can be used to make NPP, ANPP, 4-AP and norfentanyl. All four substances are listed in Table I of the 1988 Convention.
- 1-Boc-4-piperidone is a chemically protected derivative of 4-piperidone and can be used to make 1-boc-4-AP and subsequently norfentanyl. Both substances are listed in Table I of the 1988 Convention. 1-Boc-4-piperidone may also be converted back into 4-piperidone.
- The final products, fentanyl and fentanyl analogues, are very potent narcotic drugs, typically 10-100 times stronger than heroin. Their high potency continues to result in overdose deaths in users and in inadvertent exposure of law enforcement personnel and other personnel along the distribution chain.
4) In making its assessment pursuant to article 12, paragraph 4, of the 1988 Convention, the Board finds that:
a) The volume and extent of public health or social problems caused by illicitly manufactured fentanyl and fentanyl analogues are issues that warrant international action.
b) 4-Piperidone and 1-boc-4-piperidone are very suitable precursors for the illicit manufacture of fentanyl and a number of fentanyl analogues. Incidents of illicit use involving the two substances have been reported since 2019.
c) There is limited known legitimate manufacture of and trade in4-piperidone and 1-boc-4-piperidone, limited to small amounts, typically for research and development purposes.
5) In light of its findings, the Board recommends adding 4-piperidone and 1-boc-4-piperidone to Table I of the 1988 Convention. International control of the two substances will limit their availability for illicit drug manufacture and subsequently reduce the quantity of fentanyl and fentanyl analogues manufactured illicitly from them.
6) The Board is of the view that the proposed controls will have no adverse effect on the availability of the two substances for any of the limited known legitimate uses.
7) Placement in Table I will provide Governments with the possibility to request pre-export notifications as a means of monitoring shipments entering their territories.
I thank you for your attention.
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INCB Statement 2: P-2-P methyl glycidic acid and eight of its esters
Mr. Chair, Excellencies, Ladies and Gentlemen,
1) The second set of recommendations that INCB submitted to the Chair of the Commission, again in the discharge of its functions under article 12 of the 1988 Convention, relates to the placement of nine pre-precursors of amphetamine and methamphetamine in Table I of the 1988 Convention. I would like to share a few considerations in connection with the Board's recommendations:
2) What all nine substances have in common is that:
a) They are chemically very closely related substances and can all be used interchangeably in the illicit manufacture of P-2-P, a chemical already listed in Table I of the 1988 Convention; and
b) They are all designer precursors, purpose-made chemicals with no known legitimate uses and no regular trade.
3) Because of the similarities, I will cover the nine substances together, in one statement. In chemical terms, they include one acid and eight of its esters.
4) In making its assessments pursuant to article 12, paragraph 4, of the 1988 Convention, the Board finds that:
5) All nine substances are highly suitable for the illicit manufacture of P-2-P, a precursor already listed in Table I of the 1988 Convention, which is in turn used in the illicit manufacture of amphetamine and methamphetamine.
6) Incidents of illicit manufacture and trafficking involving P-2-P methyl glycidic acid have been known since 2012, its methyl ester since 2016 and its ethyl ester since 2023, with increasing frequency and amounts reported since late 2022.
7) Seizures of the other six esters (the propyl, isopropyl, butyl, isobutyl, sec-butyl and tert-butyl ester) have not yet been brought to the Board's attention. However, the six esters are direct substitutes for the methyl and ethyl esters and can be converted to P-2-P using the same technology and processes.
8) There is no known legitimate manufacture of and trade in the nine substances other than in very small amounts for research and development purposes.
9) In light of its findings, the Board recommends adding all nine substances (all stereoisomers of each substance) to Table I of the 1988 Convention. International control of the nine substances will limit their availability for illicit drug manufacture and subsequently reduce the quantity of amphetamine and methamphetamine manufactured illicitly from them.
10) For the six esters (the propyl, isopropyl, butyl, isobutyl, sec-butyl and tert-butyl ester) for which no seizures have yet been brought to the Board's attention, scheduling is recommended to prevent an instant shift to those esters, effectively putting Commission resolution 65/3 of March 2022 into practice.
11) The proposed controls will have no adverse effect on the availability of the nine substances for any of the known research and development purposes, given the very limited to non-existent legitimate market for, and trade in, the substances.
12) Placement in Table I will provide Governments with the possibility to request pre-export notifications as a means of monitoring any trade in the substances.
13) Given the close chemical relationship between the substances, the Board proposes that the eight named esters be included in Table I as a footnote to P-2-P methyl glycidic acid.
Thank you for your attention.
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INCB Statement 3: Ethyl ester of 3,4-MDP-2-P methyl glycidic acid and six additional esters
Mr. Chair, Excellencies, Ladies and Gentlemen,
1) The last set of recommendations that INCB submitted to the Chair of the Commission in the discharge of its functions under article 12 of the 1988 Convention relates to the placement of seven pre-precursors of MDMA (or "ecstasy") in Table I of the 1988 Convention.
2) At the outset, I would like to note that the same considerations that I have shared in connection with the previous recommendations also apply here:
a) The seven substances are very closely related with each other and with two substances listed already in Table I of the 1988 Convention, namely 3,4-MDP-2-P methyl glycidic acid and its methyl ester; Chemically they are all esters;
b) All of these substances can be used interchangeably in the illicit manufacture of 3,4-MDP-2-P, a chemical already listed in Table I of the 1988 Convention; and
c) They are all designer precursors, purpose-made chemicals with no known legitimate uses and no regular trade.
3) Because of the similarities, I will cover the seven substances together, in one statement:
4) In making its assessments pursuant to article 12, paragraph 4, of the 1988 Convention, the Board finds that:
5) All seven substances are highly suitable for the illicit manufacture of 3,4-MDP-2-P, a precursor already listed in Table I of the 1988 Convention, which is in turn used in the illicit manufacture of MDMA and related substances.
6) Incidents of illicit manufacture and trafficking involving the ethyl ester of 3,4-MDP-2-P methyl glycidic acid have been known since 2021, with a major increase in frequency and amounts reported since the end of 2022.
7) Seizures of the other six esters (the propyl, isopropyl, butyl, isobutyl, sec-butyl and tert-butyl ester) have not yet been brought to the Board's attention. However, the six esters are direct substitutes for the ethyl ester [and the already controlled methyl ester] and can be converted to 3,4-MDP-2-P using the same technology and processes.
8) There is no known legitimate manufacture of and trade in the seven substances other than in very small amounts for research and development purposes.
9) In light of its findings, the Board recommends adding all seven substances to Table I of the 1988 Convention. International control of the seven substances will limit their availability for illicit drug manufacture and subsequently reduce the quantity of MDMA manufactured illicitly from them.
10) For the six esters (the propyl, isopropyl, butyl, isobutyl, sec-butyl and tert-butyl ester) for which no seizures have yet been brought to the Board's attention, scheduling is recommended to prevent an instant shift to those esters, effectively putting Commission resolution 65/3 of March 2022 into practice.
11) The proposed controls will have no adverse effect on the availability of the seven substances for any of the known research and development processes, given the very limited to non-existent legitimate market for and trade in the substances.
12) Placement in Table I will provide Governments with the possibility to request pre-export notifications as a means of monitoring any trade in the substances.
13) Given the close chemical relationship between the substances, the Board proposes that the seven named esters be included in Table I as a footnote to 3,4-MDP-2-P methyl glycidic acid, which has been under international control since November 2019.
Thank you for your attention.
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