The list of concerns about Iran is long, ranging from human rights violations to its nuclear program. But largely underrepresented in the public policy discourse is Tehran’s non-compliance with the 1997 Chemical Weapons Convention (CWC)—especially its work on pharmaceutical-based agents (PBAs) for offensive military or other harmful purposes.

CWC Concerns

The CWC bans state parties from developing, producing, acquiring, stockpiling, retaining, transferring, assisting, encouraging, inducing, and or using chemical weapons.REF Any existing chemical weapons or production facilities must be declared and destroyed.REF

Iran signed and ratified the CWC in 1997. But the U.S. government claims that Iran is in violation of the CWC for several reasons, including that Tehran has an undeclared chemical weapons program.REF

Specifically, Iran has not disclosed to the Organization for the Prohibition of Chemical Weapons (OPCW)—the implementing body of the CWC—its transfer of chemical weapons to Libya in the 1980s, and has not submitted a comprehensive declaration of its chemical weapons facilities nor declared its holdings of riot-control agents (RCAs).REF

Much less specific in open source is the Trump Administration’s apparent deep concern that Iran is pursuing central-nervous-system- (CNS-) acting chemicals, including PBAs, for offensive purposes.REF The State Department reports that at least two Iranian-military-controlled facilities have researched chemical agents with incapacitating effects, and Iranian papers cite the potential military uses of PBAs.REF

These PBAs could include, among others, the synthetic opioid agent fentanyl and analogues, such as carfentanil.REF These powerful opioids could be used to incapacitate or kill those who ingest, inhale, or absorb it trans-dermally—even in minute dosages.REF

While PBAs have civilian purposes in medicine and veterinary science, the military preparation and warfare use of these agents would violate Article 1 of the CWC.REF

Using this type of CNS-acting agent would not be unprecedented in a military or paramilitary scenario: Russian security services used a fentanyl variant in its attempt to liberate 800 hostages held by Chechen terrorists at Moscow’s Dubrovka Theater in October 2002.REF Pumping powerful carfentanil gas into the theater to incapacitate the seemingly well-armed terrorists, some 120 hostages died, apparently from exposure to the opioid.REF

Among a number of other potential scenarios for its unconventional or conventional military use, these extremely potent pharmacological agents could also be furtively introduced into water, food, or agricultural systems, or could be aerosolized.REF

Tehran and Its Troubling Ties

Weapons of mass destruction—of any sort—in the hands of the Iranian regime are reason for significant concern.

Indeed, Tehran could certainly use PBAs for both internal and external security purposes. Domestically, beyond the possible use of RCAs against protestors, while much riskier from a health or political standpoint, Tehran could escalate and use CNS-acting agents against those who resist, or demonstrate against, controversial regime policies.

While there has been no known use of CNS-acting agents internally, Tehran used chemical weapons externally against Iraqi forces during the Iran–Iraq War in the 1980s.REF With this is mind, Iran’s illegal incapacitating agents could also be used in its international adventurism. For instance, Tehran is currently supporting the regime of Syrian President Bashar al Assad in an ongoing civil war that has witnessed Damascus using chemical weapons against regime opponents to significant effect.

While of lower probability, Iran could also supply the Houthi rebels with chemical weapons for use against anti-rebel forces in Yemen’s civil war, or even supply PBAs to Iran-backed popular mobilization units in Iraq, endangering U.S. interests there.

Equally concerning are Iran’s ties to terrorism. Indeed, Iran has been on the U.S. State Department’s State Sponsor of Terrorism list since 1984. Today Tehran is considered the “world’s leading state sponsor of terrorism.”REF Iran’s ties to capable, well-established foreign terrorist organizations (FTOs), such as Hamas and Hezbollah, are well known.

Iran devotes significant resources, including the provision of financial and military means, to support these FTOs in advancing the political-military agendas of both Iran and these terror groups—which have Middle Eastern, or even global, reach.

It is possible that Iran, its allies, and its non-state proxies could use Iranian-produced chemical weapons such as fentanyl and its analogues against Tehran’s opponents and others. There targets could include U.S. interests, such as American diplomats, facilities, citizens, and military forces, as well as those of allies, friends, and partners.

In light of these issues and ongoing tensions with Iran, the Administration should:

• Speak out publicly at the highest levels, starting with the President, Vice President, or Secretary of State, on U.S. concerns about Iran’s chemical weapons programs to improve international awareness, and deter and dissuade Iranian involvement with chemical weapons, especially PBAs.
• Add Iranian compliance with the CWC to the list of existing U.S. demands, such as those on Tehran’s nuclear and missile programs, for improving relations with the United States.
• Highlight more broadly in diplomatic and international security interactions and fora Iran’s non-compliance with the CWC, especially concerns about work on PBAs for offensive purposes.
• Take action at the OPCW against Iran. Pending Tehran’s full and verifiable compliance with the CWC, steps could include censuring Iran and suspending its membership or voting rights. Another option is calling for the removal of Iran’s OPCW representative, who is serving as vice chair of the OPCW executive council.

Congress should:

• Conduct specific hearings that focus on Iran’s chemical weapons programs, especially PBAs, and their potential offensive threat to U.S. interests from both Tehran and its terror proxies. Besides educating lawmakers, these hearings will raise public awareness.
• Emphasize, during interactions with foreign officials, the need for their countries to support a CWC ban on the aerosolization of fentanyl and its analogues as inconsistent with the CWC’s law enforcement exception.

Conclusion

Despite an international agreement’s prohibition of the possession, production, and use of chemical weapons, recent use as a weapon of war, terror, and assassination by both state and non-state actors is alarming—and an emerging threat. The recent, regular use of chemical weapons in a variety of scenarios could lower the reluctance to employ it, undermining the international norm on prohibition.

Considering Tehran’s threats to international security, the United States must deter, dissuade, and prevent Iran and its proxies from developing and using chemical weapons against U.S. interests.

Peter Brookes is Senior Research Fellow for Weapons of Mass Destruction and Counter Proliferation in the Center for National Defense, of the Kathryn and Shelby Cullom Davis Institute for National Security and Foreign Policy, at The Heritage Foundation.