Compliance With the Convention on the Prohibition of the Development, Production, Stockpiling and Use of Chemical Weapons and on Their Destruction (Excerpts)

April 19, 2022

Weapon Program: 

  • Chemical



The United States certifies Iran is in non-compliance with the CWC due to (1) its failure to declare its transfer of CW to Libya during the 1978-1987 Libya-Chad war, (2) its failure to declare its complete holdings of Riot Control Agents (RCAs), and (3) its failure to submit a complete CWPF declaration.  Further, the United States has concerns that Iran is pursuing PBAs and toxins with utility for CW applications for offensive purposes.


In accordance with CWC Article III, paragraph 1(a) (iv), each State Party is required to “declare whether it has transferred or received, directly or indirectly, any chemical weapons since 1 January 1946 and specify the transfer or receipt of such weapons.” The United States assesses that in 1987 Iran transferred CW munitions to Libya during the 1978-1987 Libya-Chad war.  Following the collapse of the Gaddafi regime, the Libyan Transitional National Council located sulfur mustard-filled 130-millimeter (mm) artillery shells and aerial bombs, which are assessed to have originated from Iran in the late 1980s.  In 2011, Libya declared to the OPCW that it discovered 517 artillery shells and 8 aerial bombs comprising 1.3 metric tons (MT) of sulfur mustard but did not address the provenance of the items.  Iran never declared this transfer in accordance with Article III, paragraph 1(a)(iv) of the CWC, and Iran never responded to an OPCW request for additional information.

In accordance with Article III, paragraph 1(e) each State Party is required to declare, with respect to RCAs, the chemical name, structural formula, and Chemical Abstracts Service registry number, if assigned, of each chemical it holds for riot control purposes.  States Parties are further obligated to update the declaration not later than 30 days after any change becomes effective. The United States assesses that Iran’s RCA declaration is incomplete.  Iran has developed several RCA options – specifically the irritant dibenzoxazepine (CR) – and since 2012, Iran has marketed them for export for riot control purposes.  However, Iran has not declared that it holds CR for riot control purposes.  

In accordance with CWC Article III, paragraph 1(c)(i) and (ii), each State Party is required to “[d]eclare whether it has or has had any chemical weapons production facility under its ownership or possession, or that is or has been located in any place under its jurisdiction or control at any time since 1 January 1946” and “[s]pecify any chemical weapons production facility it has or has had under its ownership or possession or that is or has been located in any place under its jurisdiction or control at any time since 1 January 1946, in accordance with Part V, paragraph 1, of the Verification Annex.”  Further, Part V, paragraph (1)(c) of the Verification Annex requires a “statement of whether it is a facility for the manufacture of chemicals that are defined as chemical weapons or whether it is a facility for the filling of chemical weapons, or both.” In light of the discovery of chemical-filled artillery projectiles and aerial bombs, the United States assesses that Iran filled and possessed CW munitions.  The United States also assesses that Iran successfully developed mortars, artillery cannon rounds, and aerial bombs for CW agent delivery during the 1980-1987 Iran-Iraq War, but failed to declare a CWPF with respect to weapons filling.

The United States is also concerned that Iran is pursuing chemicals for purposes inconsistent with the CWC, based on Iranian scientific publications.  Specifically, Iran’s work on PBAs, which it refers to as “incapacitating chemical agents,” raises serious concerns that Iran is pursuing these agents for offensive purposes, which would be a violation of Article I.    


Iran signed the CWC on January 13, 1993, ratified the CWC on November 3, 1997, and submitted its initial declarations in 1998 and 1999.  Previous Condition (10)(C) Reports and compliance reports have addressed Iran’s sulfur and nitrogen mustard production before entry into force.  Iran did not declare any CW weapons or agent stockpiles.  

Lack of Declaration on Transfer of Chemical Weapons to Libya

Iran is assessed to have transferred CW munitions to Libya during the 1978-1987 Libyan-Chad war.  Specifically, Iran is assessed to have transferred sulfur mustard-filled munitions to Libya in 1987.  After the collapse of the Gaddafi regime in 2011, the Libyan Government located newly found munitions that it suspected were of a chemical nature, which are assessed to have originated from Iran in the late 1980s.  

Figure 13 - Photographs of the 517 130-mm artillery shells declared by Libya.  The Persian markings on the cases (inset) translate to 01-G-S-Gh (meaning unknown) and 65-01 (likely a manufacture date of Farvardin 1365, corresponding to March/April 1986). 

After declaring the 130-mm artillery projectiles in 2011, Libya requested OPCW TS assistance in collecting information relating to these chemical weapons.  Pursuant to this request, the TS, on December 19, 2012, invited “States Parties, should they be aware and/or in the possession of any information that could contribute to resolving this issue, or should they need any additional information and/or clarification in this regard, to directly contact the National Authority of Libya, or the Permanent Representation of Libya to the OPCW” (NV/VER/DEB/180682/12).  Iran has never declared that it transferred chemical weapons to Libya, including in response to the TS’s request. 

Lack of Complete Declaration on Riot Control Agents

Although Iran has not declared that it holds CR for riot control purposes, the Iranian Ministry of Defense publicly advertises a range of RCA delivery devices, including a personal defense spray that contains CR.  Additionally, Shahid Meisami Group (SMG) has participated in defense expos providing fact sheets on its products, to include an 'Ashkan' irritant hand grenade that creates smoke containing CR.  SMG has also provided fact sheets to interested users on a “Fog Maker System” that can be used to make smoke and fog at high volume in a short time.  This is noteworthy because it can disseminate debilitating chemicals, like CR, over a large area quickly. 

Lack of Complete Declaration on CWPFs  

Although Iran never declared a CWPF with a filling capability to weaponize its chemical agent, reports of Iranian-filled CW munition use during the Iran-Iraq war indicate that Iran had such a capability.  In April 1987, mustard-filled 130-mm artillery projectiles believed to be of Iranian origin were used near Basrah, Iraq.  Iraq’s military and a United Nations (UN) delegation in Iraq reported the artillery contained residual sulfur mustard agent, and Iraqi casualties displayed burns consistent with mustard exposure.

During a United Nations Special Commission (UNSCOM) inspection in 1991 at Iraq’s Muthana State Establishment, UN inspectors found 165 81-mm mortars filled with sulfur mustard that the Iraqis claimed were Iranian origin (image).  Iraq did not possess or fill 81-mm mortars with mustard and the subsequent laboratory tests concluded that the agent in the munitions had higher levels of sulfur mustard impurities than those typically found in agent made by the Iraqis at Muthana, suggesting the munitions were not made by the Iraqis or made at that location.

Work on PBAs and Toxins

Since 2005, some of Iran’s military-controlled facilities, Imam Hossein University (IHU) and Malek Ashtar University of Technology (MUT), have researched chemicals that have a wide range of sedation, dissociation, and amnestic incapacitating effects.  Published Iranian papers cited the potential weapons applications of the PBAs; one specifically referenced the use of fentanyl during the 2002 Dubrovka theater hostage crisis.  In 2014, Iran’s Chemistry Department of IHU sought kilogram quantities of medetomidine – a sedative it has researched as an incapacitant – from Chinese exporters.  The Chemistry Department has little history of veterinary or even medical research, and the quantities sought (over 10,000 effective doses) were inconsistent with the reported end use of research.

The United States is also concerned that Iran is developing toxins and bioregulators as chemical weapons.  Toxins are toxic chemicals produced by living organisms.  Bioregulators are a class of natural chemicals in the human body that control vital bodily functions.  Iran has engaged in dual-use activities with potential for BW and CW applications, such as building a plant for pharmaceutical botulinum toxin production.  Iranian biotechnology entities, particular militaryaffiliated institutions, continued to pursue dual-use technologies.  Open-source reports note Iranian military-associated universities and affiliated research centers have conducted BWrelevant projects on bioregulators and have built a plant for the commercial production of botulinum toxin.  The United States has raised similar concerns in its annual Compliance Report related to the BWC.


On November 22, 2018, the United States addressed Iran’s non-compliance with the CWC in its national statement to the CWC’s Fourth Review Conference.  The statement included findings from the November 20, 2018, Report to Congress detailing Iran’s non-compliance with the CWC.  The United States reiterated this finding in its 2019 and 2020 national statements to the CWC Conference of the States Parties.  In 2019, the G7 also issued a statement of concern about Iranian CWC compliance further reinforcing the U.S. non-compliance finding.  In its 2020 national statement to the CSP the United States specifically called on Iran to take action and made clear that the United States would consider actions, including sanctions, in response to Iran’s CWC non-compliance.  Following the national statement at the CSP, on December 3, 2020, the United States designated Iranian defense entity SMG under Executive Order 13382 because of its responsibility for projects involving the testing and production of chemical agents for use as so-called incapacitation agents.  SMG’s director, Mehran Babri, was also designated. 

As noted above, in part to address concerns about Iran’s work on PBAs, the United States led an effort at the OPCW that concluded with the adoption of a CSP decision affirming that “the aerosolized use of CNS-acting chemicals is understood to be inconsistent with law enforcement purposes as a ‘purpose not prohibited’ under the Convention.”  Iran, along with Russia, the PRC, and Syria, was a principal opponent of the decision. 

While the United States remains concerned about the regime’s true intent with regard to the testing and production of these so-called chemical incapacitating agents, which could be used for offensive purposes, including against Iranian citizens, the United States will continue to work to shed light on Iran’s activities, including by highlighting the recently adopted CSP decision.  No bilateral discussions with Iran occurred during the 2021 reporting year.  The last CWC compliance-related bilateral exchanges occurred in 2001 and 2004, on the margins of OPCW EC meetings, but discussions did not resolve any of the issues raised by the United States.