The Illegal Trade in Chemicals

Trade strategies

As with legitimate products, illicit pesticides reach the market through imports and domestic production. The techniques for importing illegal pesticides include: • Standard smuggling methods (disguising the product; splitting containers into small batches; changing the weight) • Incorrect HS Code or Group (veterinary drugs instead of patented insecticide, e.g.) • Forging Registration Certificates or shipping documents • Long logistics chains that require additional document checking • Incorrect or missing labels (mislabeling, labels that are hard to read; labels with incomplete information; labels in foreign languages) • Online sales via applications such as WhatsApp, Instagram and Facebook The marketing of pesticides online is a developing global trend, and different types of illegal pesticides are available (US EPA 2018a; Ecologist 2018). Unregulated online marketing, sometimes coupled with anonymous delivery, complicates traceability, and allows criminals to target uninformed buyers. Online trade simplifies the purchase of plant protection products, and reduces the cost. Manufacturers, distributors and pest control operators all maintain websites. Plant protection products are also available from online retailers and auction sites, on illegal trade sites with no fixed addresses and on the dark web. Not all of these types of sites are intentionally involved in trading illicit pesticides. In general, analyses of online trade of chemicals are rare as this is an emerging trend that requires a specific approach, but some concrete examples such as the distribution of unauthorized pesticides on Amazon reveal its importance.

Corruption and lax enforcement – often coupled with relabeling – allow for the return of seized stocks to the market. In countries with no empty container management system for handling used pesticide containers, especially those with a substantial informal economy, illegal traders buy used containers and fill them with substandard or obsolete stocks. It has been 10 years since Kyrgyzstan ratified the Stockholm Convention, which regulates obsolete pesticides among other persistent organic pollutants. During this period, the amount of obsolete pesticide stockpiles in the country has declined by 50 per cent, but the country did not take any measures to dispose of obsolete pesticides. The clear implication is that the reduction in the amount of obsolete pesticides occurred as a result of their illegal use, which may have included open burning and applications on private land.

The illegal trade in domestically produced pesticides also includes online sales as well as the following:

• Production of illicit pesticides from legally imported active ingredients (see Annex 1) • Relabeling or repackaging of pesticides in small containers to meet the demand of small-scale farmers (see street market in Ukraine, below)

• Seized stocks returned to the market • Reuse of original pesticide containers • Garage blending and dilution (see Annex 1) • Use of banned pesticides from stockpiles

Some countries have no restrictions on importing active ingredients that can be used to manufacture pesticides, and relabeling or repackaging is popular among counterfeiters.

A street market in Ukraine where traders sell glyphosate stored in Coca-Cola bottles to be poured in consumer containers on demand. Chemicals for sale are often next to food items.

The Illegal Trade in Chemicals

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