The Illegal Trade in Chemicals

Selected national enforcement efforts

The United Nations Office for Drugs and Crime together with the World Customs Organization implements the Container Control Programme with the aim of assisting Governments in creating sustainable enforcement structures in selected seaports, airports and land border crossings in order to minimize the risk of cargo containers being exploited for illicit drug trafficking, transnational organized crime and other forms of black market activity. The reports from the custom units on the interception of illegal shipments of chemicals are few compared to the activities related to global transboundary trade in chemicals, possibly as a result of a lack of knowledge and awareness, but the programme reports regular seizures of a wide range of contraband including precursor chemicals and goods that are counterfeit or otherwise violate intellectual property rights (UNODC 2015; UNODC 2016; UNODC 2017).

followed by imidacloprid, emamectin benzoate and fipronil • Four active ingredients prohibited or banned in Brazil – Metalaxyl, Benomyl, Methamidophos and Monocrotophos – were detected • The toxicity of the seized chemicals ranged from extreme (13%); to high (22%); moderate (53%); and low (9%)


According to a high ranking official at the Criminal Investigation Agency, between September 2017 and March 2018, Indonesian police confiscated about 35 tonnes of mercury and 36 tonnes of cinnabar, and identified 125 suspects in the illegal trade in mercury. An official statement reported 40 tonnes of mercury and 26 tonnes of cinnabar confiscated in 2017 (TribrataNewsNTB 2017). The largest mercury raid in Indonesia occurred in Semarang harbour in central Java in September 2017, and involved a Sudanese citizen ultimately sentenced to prison for one year and fined about US $68,000. This illegal trader bought mercury in lots and stored them in boxes in a rented warehouse in the Semarang Port, Tanjung Mas. One lot of 10 tonnes came from an Indonesian trader via the Internet at a price of almost US $30,000. Another purchase came from the city of Bekasi, and was trucked to storage in the Semarang warehouse. When the local police raided the warehouse on the basis of suspiciousmovements,theyfound21tonnesofmercuryinboxes. Police confiscated the mercury, and found no proof of origin, no licence, no permit. The Sudanese citizen, a warehouse worker and the warehouse owner were all charged and convicted under Indonesian law for the illegal trade in mercury. The warehouse worker was sentenced to two years in prison and fined about US $10,000, and the owner was sentenced to seven months in prison and fined about $3,400 (CNN Indonesia 2017). Early in 2018, the US Environmental Protection Agency announced an agreement with Amazon, the largest US e-commerce platform, on unregistered and mislabeled pesticides sold through Amazon’s website between 2013 and 2016 (US EPA 2018a). These sales violated the US Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). The US is not a Party to the Basel, Rotterdam and Stockholm Conventions, but FIFRA set up strict rules regarding the registration, labelling and sales of pesticides in the US in order to protect public health and the environment. The EPA is responsible for the enforcement of FIFRA, and controls the import of pesticides and inspects the labelling of those products. The United States

Annex 3 includes a summary of media accounts of recent national enforcement caseswherechemicalswere intercepted.


According to SINDIVEG, the Brazilian agrochemical industry trade association, the Brazilian authorities seized 496 tonnes of illegal pesticides between 2001 and 2013. In 2016, this amount reached 654 tonnes, and in July 2018 the SINDIVEG website reported 1,125 tonnes of seizures (SINDIVEG 2018).

News reports suggest a wide variation in seizures of illegal pesticides:

• From a few kilograms to tens of tonnes • Fromordinary cars to large trucks, ships, boats and airplanes • In transit and in storage • Illegal imports and clandestine factories • Illegal, clandestine, counterfeited and smuggled products TheToxisphera Environmental HealthAssociationnotes that the illegal products do not meet the legal requirements regarding limits of impurities (and therefore, could not be registered in Brazil). Some products may not even have active ingredients, and in one case the product had 25 active ingredients of different chemical groups, classes of use and risk, and included insecticides, acaricides, formicides, termicides and fungicides, and even a growth regulator and herbicide (Tosato 2017). A study based on expert reports produced by the Brazil Federal Police between January 2012 and October 2017 (Lemos, Carvalho and Ortiz 2018) points out that: • Eighteen per cent of seizures had no active ingredients, or had ingredients other than those described on the package • Metsulfuron-methyl was the active ingredient most frequently present in pesticides seized and analyzed,

The Illegal Trade in Chemicals


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