(In Progress)Data project with visualization: Mysterious flows of Chemical Weapon Precursors from European Union

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*Link to Interactive Sankey Diagram: 



Blistered skin, inflamed eyes and burned lungs — this is what over 800 Iraqi people suffered on March 13, when two chemical attacks took place near the northern Iraqi city of Kirkuk. Mustard gas, an inhumane blister agent that was extensively used during World War I, tortured and killed three children — a 10-year-old girl, a 3-year-old girl and a six-month-old baby.


But the Islamist terror group didn’t necessarily have to buy or steal the gas — they have the ability to make it, and other lethal chemical weapons.


“There are reports that ISIS has access to chemical precursors and munitions that they can use, ” said John Brennan, the CIA director, during an interview in CBS “60 minutes.”


Most precursors—chemical compounds—that can be reacted to produce chemical weapons such as nerve agent Sarin and blister agent mustard gas, are needed for various industries and can be seen everywhere in our daily life. Hydrogen Fluoride, for instance, can be used to produce Sarin, which paralyses muscles and one’s ability to breathe, but on the other hand, supports cleaning and disinfecting industries.


Chemicals like these are known as dual-use chemicals.


In theory, when these chemicals travel from country to country through trade, they are carefully tracked to make sure they don’t fall into the wrong hands. However, in practice oversight is thin and varies greatly by country. Some chemicals, like the chemical precursor of mustard gas, aren’t subject to special controls at all.


One of the dual-use chemicals, Monoethylene glycol (MEG), that can be produced to mustard gas, was found exported from Belgium to Iraq last year. At least 60 tons in total — this is the first time since 2004 that Iraq received exports of MEG that is over a thousand kilogram from Europe,according to a new data analysis of 10 year of European trade data from Eurostat, the statistics department of the European Commission.


Until today, MEG hasn’t been included on European Union export control list.


“It adds more steps to the preparation of the mustard agent and thus requires more effort to produce the mustard agent,” said Dr. Jonathan E. Forman, the Science Policy Adviser at Office of Strategy and Policy at the Organization for the Prohibition of Chemical Weapons (OPCW.)


Mark Bishop, a Canadian chemist and the author of educational textbook “An Introduction to Chemistry,” breaks down this chemical process: MEG could be converted first to 2-chloroethanol, a chemical that is on one of the international export control list (Australia Group’s Common Control List), and 2-chloroethanol can react with sodium sulfide to form thiodiglycol, the trade of which is also controlled; reacting with hydrochloric acid, thiodiglycol can be converted into mustard agent — the lethal and inhuman chemical weapon that tortures the innocent to death.


“The more common the substance is, the more difficult it is to control it, “ said Bishop. According to Dr. Forman, MEG can be used for the manufacture of a wide range of products, including resins, deicing fluids, heat transfer fluids, automotive antifreeze and coolants, textile fibers, paper and leather.


“So without knowing who was receiving it and for what purpose it was purchased it’s not really easy to say if there is a problem,” Dr. Froman added.


“It will be difficult to produce chemical weapons without hurting themselves, if they [terrorists] are not well-trained like us [chemistry experts],” Professor Jack Norton from Chemistry Department, Columbia University, provided a similar perspective.


For a decade, MEG has been disputed for its proliferation risks. In 2006, the Dutch Minister of Foreign Trade and Development wrote a report on the possible use of MEG in the production of mustard gas. Two years later, they proposed to include MEG into the one of the international export control list (Australian Group), but failed.


Apart from unprecedented exports from Belgium to Iraq last year, the trade data also shows that 60 million tonnes and 30 million tonnes of MEG were exported to unspecified countries and territories outside EU from Netherlands in 2007 and in 2015, respectively.


“We have unknown partners [countries that import goods from EU countries] in the cases that the partners is hidden for confidential reasons or in cases that the data are estimated, not collected, at more aggregated level,” said Evangelos Pongas from Eurostat.


For the dual-use chemicals that are on the EU export control lists, they also flow into unspecified areas. In 2005 and 2006, France exported around € 70 million of dual-use chemicals that are listed on EU Export Control List to countries and territories unspecified within the framework of trade with third countries.


If the countries are unidentifiable, how to guarantee that these chemicals would not slip into hands of terrorists or extremists?


EU countries are one of the largest exporters of chemicals and the profit made from dual-use chemicals has never stopped booming. According to the trade data analysis, the dual-use chemicals are becoming a larger share of chemical exports for EU countries. In 2000, the monetary amount of dual-use chemicals only take up 4 percent of the monetary amount of all the chemical exports from EU countries. For 14 years, the ratio has been increasing; it peaked in 2011 with a percentage of 16.35, as is shown in the graphic 1.

Graphic 1 Dual-use chemicals are becoming a larger share of EU chemical exports (value in Euro)


What accompanies this increased trade of dual-use chemicals is the growing economic gains. On average, from 2000 to 2014, the proportion of dual-use chemicals of all the chemicals that each EU country has exported has increased almost 10 percent.


Percentage of dual-use chemicals among chemical exports in EU countries 2000-2014



Dual-use chemicals are closely associated with industries and their economic values are inestimable. From 2010 to 2014, EU countries exported approximately € 1,200 billion of dual-use chemicals that are under EU Export Control List to non-EU countries every year.

Without law enforcements and strict export controls, a company can benefit a lot from the dual-use chemicals, if it underestimates the risks of proliferation. Similarly, if a country focuses on the short-term economic gains, it is likely to find bureaucratic inertia in their custom offices and export control systems. After all, tracking the movement and uses of an item is difficult and a country may find it less accountable.



Today, the implementation of export controls totally depends on national authorities. Even in the EU context, each EU country has a final say on their licensing process and export control systems.


“The EU does not control the actual exporting licensing officers as you may know. These operate under a national mandate, when implementing EU regulations,” said Dr. Anna Wetter, who is the senior researcher in law at Swedish Institute for European Policy Studies (SIEPS). She wrote a research report in 2008, Enforcing European Union Law on Exports of Dual-use Goods, which was published by Stockholm International Peace Research Institute (SIPRI.)


The EU regulation she mentioned is the Regulation No 428/2000, which sets the overall framework for export control policies for all the EU countries. According to the EU Regulation, most responsibilities on licensing authorizations to export and transfer toxic chemicals are left in the hands of national custom offices in each European countries.


Besides the control rules and the collaborations throughout the EU, the EU regulation also provides a EU Dual-use Control List — a list of items that can be used for Weapon of Mass Destruction (WMD) application. When a company intends to export any item from this list, it requires a license from national authorities.


“This [EU Dual-use Control List] synthesises the control lists that are agreed in the different export control regimes and is directly applicable in EU national legislation, ” said Mark Bromley, the co-director of Dual-Use and Arms Trade Control Programme at Stockholm International Peace Research Institute (SIPRI).


The EU regulation she mentioned is the Regulation No 428/2000, which sets the overall framework for export control policies for all the EU countries. According to the EU Regulation, most responsibilities on licensing authorizations to export and transfer toxic chemicals are left in the hands of national custom offices in each European countries.


Besides the control rules and the collaborations throughout the EU, the EU regulation also provides a EU Dual-use Control List — a list of items that can be used for Weapon of Mass Destruction (WMD) application. When a company intends to export any item from this list, it requires a license from national authorities.


“This [EU Dual-use Control List] synthesises the control lists that are agreed in the different export control regimes and is directly applicable in EU national legislation, ” said Mark Bromley, the co-director of Dual-Use and Arms Trade Control Programme at Stockholm International Peace Research Institute (SIPRI).


In other words, the EU list incorporates all the items from the following four international export control regimes: Nuclear Suppliers Group(NSG), Missile Technology Control Regime (MTCR), The Australia Group(AG) and Wassenaar Arrangement (WA). The Australia Group specifically targets on the chemical and biological weapons.


On top of these regimes is the Chemical Weapon Convention (CWC), an international arms enacted by OPCW in 1993. Internationally, all the countries, except Egypt, Israel(signed but not ratified), North Korea and South Sudan, signed and ratified the CWC. CWC provides three export control lists of dual-use chemicals for all the national authorities: Schedule 1, Schedule 2 and Schedule 3.


“Schedule 2 and 3 chemicals…can be exported and imported between countries that are State Parties to the Chemical Weapons Convention,” explained Dr. Forman.


He said that Schedule 2 chemicals can be used as pesticides and in the production of pharmaceuticals, and some of the Schedule 3 chemicals are used in multi-million ton per year quantities in certain industries.


“Schedule 1 chemicals are tricker, but they too can have legal use,” said Dr.Froman. He gave out two examples: nitrogen mustard can be used for chemotherapy and saxitoxin is needed in medical test kits for paralytic shellfish poisoning. Besides, laboratoires can involve small amounts of chemical weapon agents for scientific experiments and tests.


Last year, European Commission published a workshop guidebook on dual-use export controls, which points out: “The Regulation does not create an environment in which similar decisions would be reached in all states.”


This guidebook points out that there are significant variations between EU countries in terms of licensing process: “Some states have fully electronic systems whereas others use paper-based systems, or a mix of the two. Some member states have automated integration with customs systems, whereas others lack such applications. Some publish target turnaround times for applications whereas others do not. Some offer services to aid exporters in order to understand the control status of the goods, whereas others do not offer such amenities.”


These significant variations question the effectiveness of the export control systems.


When it comes to international trade between a EU country and a non-EU country, the traders need to fill out a custom form called Single Administrative Document (SAD) to national custom offices. “At the end of each month, customs extracts some fields from their database and provides the respective data to the national statistical office which sends the data to Eurostat,” said Evangelos Pongas from Eurostat.


What should be reported on this form, according to British government, is the description, movements and commodity codes of the goods. The Combined Nomenclature(CN) is an eight-digit commodity code system that is widely used within European Union. It further specify the commodities on the basis of six-digit Harmonized System (HS) nomenclature that is administrated by World Custom Organization and is used by all the customs worldwide.

To track the movement and control the exports of dual-use chemicals, the CN code provides guidance.


“You should bear in mind that the Combined Nomenclature is revised annually,” said Ana Maqueda Lafuente, who works for the Comext Support Service of Eurostat. 33 of the 78 codes that identify dual-use chemicals have been through the revisions since 2000. Ms. Lafuente said the annual change aimed to incorporate new goods entering the market and clear outdated goods off the market.


On the other hand, for chemicals on the CWC Schedule 1 chemicals, which are regarded as most dangerous ones, CN code has changed most and is unable to specify one chemical. According to Taxation and Custom Union of European Commission, the 2015 CN code for Sarin is 29319080 and the one for Sulfur mustards is 29309099, but there are over 1,000 other chemicals are under CN code either 29319080 or 29309099. Also, these two codes have changed at least four times since 2000.


Besides, according to the workshop guidebook, “there is a lack of EU-wide data available in the public domain related to how states use export controls.” Conclusive data about implementation and enforcement remains elusive in most countries. This makes it challenging to analyse how the regulation is being enforced.


“If a member state does not provide us the data, then it is impossible for us to know,” said Pongas. However, he strengthened that there is no way that Eurostat would fail to find out the countries that intentionally or unintentionally misreport their exports, as Eurostat has connections with other directorates or associations that also collect data and manage information.


“I don’t have experience that a member state hided something from Eurostat, ” said Pongas.


But, the Eurostat cannot give a convincing explanation for the data that is recorded flowing to unspecified countries and territories outside EU for commercial and military reasons.


Germany and Netherlands are two largest exporters of dual-use chemicals under CWC lists (Schedule 1, 2 and 3) that flow to unspecified areas. Germany stopped such exports after 2007. In both 2013 and 2014, Netherlands exported over € 35 million of dual-use chemicals to unknown countries outside EU.


Another kind of unspecified importers are named “Stores and Provisions,” which by Eurostat’s explanation, refers to the products purchased at the port or airport in EU countries, but the economic owners remain unknown. That is to say, the final uses of these dual-use chemicals are unidentified and untraceable.


The top three EU countries that have exported dual-use chemicals that are listed in the EU Export Control List are Netherlands, Germany and Belgium. Since 2012, Netherlands has been steadily exporting almost € 80 thousand of chemicals under one custom code (2015 Combined Nomenclature code 29319080)– which also identifies Sarin — to Stores and Provisions within the framework of trade with third countries, which means trade with non-EU countries.


Export control list controls the trade of dual-use goods but they have their limitations. When an exporter is trying to export items that are not on the control list to countries that is internationally known to have weak export control systems or have potential to contribute to WMD application, this exporter has a responsibility to request an export license from national authorities. This is called the “catch-all” control.


In other words, catch-all means that an exporter needs to apply a license requirement to anything that is not on the export control list, if the exporter knows it’s going to support a WMD application.


“The education is a real key for catch all controls,” said Robert Andrew Shaw, the program director for the Export Control and Nonproliferation Program (XNP) at the James Martin Center for Nonproliferation Studies at the Middlebury Institute of International Studies at Monterey. He is also an adjunct professor for the Monterey Institute and co-teaches a graduate course on strategic trade controls and nonproliferation.


Professor Shaw said countries such as United States, Japan, United Kingdom and Germany would publish a list of countries, which is called Entity List, that exporters should be wary of even if the items they export is not on the control list. For example, exporters in United Kingdom and Germany will need licenses to export dual-use goods to Pakistan, Syria, Russia and India, because these countries are on their published list.


He used an example: if a Danish company is going to export wooden chairs, a common and harmless commodity, to labs at Syrian Strategic Research Institute that’s been known as involved in chemical and biological researches, that company still require a license from national authorities;because these chairs still contribute to these researchers, no matter how minor the contribution is.


“Basically this list is a way of telling`the exporting community: ‘OK. We publish this list of entities that we suspect of involving WMD proliferation. You now have knowledge that these entities may be connected to WMD program,’” said Professor Shaw. He has been in export control field since the middle 1990s and was an export compliance manager with Toshiba.


National authorities also publish a list of alarming conditions that exporters should report , said Professor Shaw, as it, to a larger extent, enforces exporters to take accountabilities for the end uses of their commodities.


“It is really difficult to enforce catch-all control, if you talk with enforcement agents… prosecutors,” he added.


The difficulty comes down to how to investigative and confirm if an exporter has reasons to know that their exports can contribute to WMD application.


In Sweden, an exporter can easily avoid convictions by claiming ignorance of the licensing requirement, as the Swedish law decides that prosecutors have to prove that exporters “intentionally” violate the regulation for a conviction.


“There are some successes but it’s extremely difficult. Usually, quite honestly, it’s after the effect enforcement. It’s very rare to intercept a shipping under catch up all controls before it goes out, ” added Professor Shaw.


Dr. Wetter, who published SIPRI report on EU dual-use controls in 2008, pointed out that legislative languages and penalties also vary significantly across EU countries. While Swedish prosecutors struggle to prove the intentions of exporters, German prosecutors don’t have such worries. Also, for the same illegal trading behaviors of dual-use goods, German exporters may face a five years’ imprisonment while it will be two years in Sweden.


“I would say that member states with low repressive criminal law systems would apply it [have higher risks of proliferation], if unaware of the risks associated with dual-use export,” said Dr. Wetter.


In 2013, the UK and German officials both confirmed they approved more exports of dual-use chemicals to Syria, but they all insisted that these chemicals were not misused. At the time, Chancellor of Germany, Angela Merkel, firmly stated: “According to all the findings that are at my disposal, they were used for civilian things.”


But on what basis can these officials be certain that the exported dual-use chemicals were never misused?


Since 2012, the chemical weapon attacks have intermittently taken place in Syria. According to the reports from United Nation Security Council, nerve agents, Sarin and VX, and blister agents, mustard gas, have been detected. In 2013, the largest-scale Sarin attack killed over 1700 lives took place on the Ghouta area of Damascus, which enforces the Bashar al-Assad to agree on the destruction of its lethal chemical stockpiles under the surveillance of OPCW and the United Nation.


On January 4, the OPCW announced that the “75 cylinders of hydrogen fluoride at its facility” have been disposed in Texas. This indicates the destruction of the entire chemical weapon stockpiles that declared by the Syria, which amount to over a thousand ton. In 2014, the Fact-finding Mission appointed by the OPCW declared that chlorine gas has been active in Syria. Till today, chlorine gas attacks are still active. The situation can be even worse, since the CIA just confirmed that ISIS have the capability to access to materials and knowledge to produce chemical weapons.


In order to see the trade flows of chemical weapons precursors to EU countries, this project plotted out an interactive Sankey diagram on the EU exports of chemicals that are under CWC Schedule lists to countries that are under ISIS influences: Syria, Iraq, Turkey, Algeria, Saudi Arabia, Egypt and Pakistan.



From the data analysis, Belgium is the largest exporters of chemicals on the CWC schedule lists for Algeria, Egypt, Pakistan, Saudi Arabia, Syria and Turkey, respectively. In total, Belgium exported over € 500 million of CWC Scheduled chemicals to these areas and over 80 percent are under CN code 29333999. The Euro that Belgium exported to Algeria, Saudi Arabia, Egypt and Syria far exceeds the value that any other EU country exported: Belgium exported over € 100 million scheduled chemicals to Algeria, while other EU country exported less than € 10 million.


One country stands out particularly in terms of exports of dual-use chemicals: Turkey.


According to data analysis, for the chemicals that are in the CWC Schedule lists that are exported from EU countries to non-EU countries, Turkey ranks the 12th largest non-EU importer with a quantity of approximately 120 thousand tons and an amount of € 618 million.


Last year in October, two Turkish parliament members said that Turkey has transited chemical weapons from European countries to support ISIS. Several news reports also targeted on Turkey and suggested it propels the proliferation of chemical weapons. In November, the U.S government demanded that Turkey to close 60-mile stretch of its borders with Syria as the U.S believes that ISIS have been getting support and goods they need from Turkey.


Almost a month after the demands from the White House, Turkish MP Eren Erdem admitted that the materials to produce chemical weapons sarin gas came from Turkey and arrived in ISIS camp.


Belgium, Netherlands and Germany are three largest exporters of dual-use chemicals under CWC Schedule Lists to Turkey . From 2000 to 2014, Belgium exported € 200 million of Schedule Chemicals to Turkey, nearly twice more than the amount exported by Netherland and Germany. 77 percent of Schedule Chemicals from Belgium are under CN code 29333999, the code that entails over 1000 chemicals.

Exports of schedule 2 chemicals to Syria


Belgium, has also been exporting significant dual-use chemicals that are in the CWC Schedule 2, to Syria since 2001.


The value of the Schedule 2 chemicals that Belgium exported in 2009 is over 3 million dollars, while the average value from other EU countries is 250 thousand dollars, as is shown in the graphic 2. The exports from Belgium is four times or even thirteen times more than any other EU country.


When looking closely at the Schedule 2 chemicals exported to Syria from Belgium, one familiar CN code appears again: 29333999.


What chemicals are included in 29333999?


According to Taxation and Custom Union of European Commission and Australia Group control list , there are three Schedule 2 chemicals under CN code 29333999: 3-Hydroxy-1-Methylpiperidine,3-Quinuclidinol and 3-Quinuclidone. These three chemicals have a common character: they can all be used to produce incaptilatnes BZ, a kind of neurotoxic chemical weapon that is well-known as “Agent 15.” Not as lethal as Sarin and mustard gas, BZ still causes psychotic disorders and incapacitation.


Agent 15 was found being used in Syria during 2012 and 2013. The data shows that since 2001, the chemicals under CN code 29333999 have skyrocketed tremendously and peaked in 2009. Yet, the data cannot verify that how much the BZ precursors actually contribute to this increase, but the trend is still worth looking into.


“These chemicals are commonly used for producing a wide range of pharmaceuticals,” said Dr. Forman.Such vague boundaries put a lot of demands on investigators and prosecutors if they intend to track end uses. “If the materials were purchased by a pharmaceutical company that sells large volumes of products, it may be a perfectly legitimate purchase,” he added.


Another country worths discussion is Israel. It’s one of the four countries that hasn’t ratified CWC and thus it’s on the Entity List that require exporters’ consulting with national authorities. Despite the fact, EU has exported over € 500 million dual-use chemicals to Israel from 2000 to 2014.


“Israel is something of a struggle, in terms of export control policies, because its close relationships with the U.S and the west,” said Professor Shaw. Israel is well-known to have developed and possessed several nuclear weapons. As for chemical and biological weapons, the concern will be the possibilities that chemicals float around the area.


However, Professor Shaw said, institutions that located in Israel and conducted WMD programs are on the Entity lists for catch-all controls. One classic example is that Ben Gurion University is on the U.S commerce department entity list, as it has labs to conduct researches to support Israel nuclear weapon programs.


If an U.S exporter is exporting High-performed computing equipments, normally it doesn’t require a license, unless these equipments will go to Ben Gurion University


“The restrictions are much more narrowed [on Israel] than you will find on Pakistan,” he added.


Export control list and catch-all control policies are means to ensure that dual-use chemicals only play a role in contributing our industries. However, the variations of licensing processes and export control systems across EU countries stand in the way of efficient collaborations in inspecting questionable exports.


According to the workshop guidebook, “there is a lack of EU-wide data available in the public domain related to how states use export controls.” The conclusive data about implementation and enforcement remains elusive in most countries. This makes it challenging to analyse how the regulation is being enforced.


Dr. Wetter also stated in her report that “the EU’s institutional framework suffers from the lack of some legal competences required for effective enforcement of its non-proliferation goals.” That is to say, the EU cannot intervene in each EU country’s national systems for law enforcement and thus the effectiveness of export control remain questionable, especially considering that each country has its own operation systems.


“It is however difficult to draw the conclusion that this is a bigger challenge for an organization such as the EU, compared to nation state control, since in many cases the illegal exports are the result of mismanagement by the national authorities,” said Dr. Wetter.


“I think that the EU is still trying to figure out how to efficiently track and control the chemicals already on the Australia Group list, ” said Bishop. He envisioned that some chemicals that could be in a reaction sequence to form chemical weapons will remain uncontrolled in the near future. To reach this future, the EU need to enhance the law enforcement, the education and collaborations on export controls.


Even though the OPCW successfully destroyed all the chemical stockpiles in Syria, it fails to terminate the mustard gas and chlorine gas attacks. An inconvenient truth is that the export controls have been constantly facing challenges.


It is the time to raise a question: has the EU controlled dual-use chemicals from being misused?



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