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Comments sought on proposed chemical trade restrictions

Five chemical families have been proposed for addition to Schedule 1 of the Chemical Weapons Convention.

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The Bureau of Industry and Security (BIS) is seeking public comment on the commercial impacts of the proposed addition of five chemical families to Schedule 1 of the “Annex on Chemicals” to the Chemical Weapons Convention (CWC), BIS said in a Federal Register notice published August 13.

The CWC is an international arms control treaty limiting the production, stockpiling and use of chemical weapons and their precursors.

Schedule 1 chemicals and precursors have been identified by the CWC as posing a high risk to the object and purpose of the convention, and the CWC places restrictions on the production of such chemicals for protective purposes.

The U.S. implements CWC provisions that affect commercial activities involving Schedule 1 chemicals through the Chemical Weapons Convention Regulations, which, among other things, bans the import of Schedule 1 chemicals from states not party to the CWC; requires advance notification and annual reporting of all imports and exports of such chemicals to or from other parties to the convention; and bans the export of such chemicals to states not party to the convention.

The U.S., Canada and the Netherlands on October 16 proposed to add two families of chemicals to Schedule 1, and Russia on December 7 made additional proposals, including adding three other families to Schedule 1.


The CWC States Parties haven’t reached agreement on adding the five chemical families to Schedule 1.

The five chemical families are:

·         P-alkyl-N-fluorophosphonyl amidines;

·         О-Alkyl-N-fluorophosphorylamidines;


·         Р-alkyl-N-fluorophosphonyl guanidines;

·         Carbamates (quaternaries and bisquaternaries of dimethylcarbamoyloxypyridines);

·         And fluorophosphoryl dihaloformaldoximes (also referred to as substituted ((alkyliden)amino)oxy-phosphates and phosphonates).

“BIS is seeking public comments to assist in determining whether the legitimate commercial activities and interests of chemical, biotechnology and pharmaceutical firms in the United States would be significantly harmed by the limitations that would be imposed on access to, and production of, the compounds included in the five chemical families identified above, if the CWC States Parties were to agree to add these chemical families to ‘Schedule 1’ in the CWC ‘Annex on Chemicals,’” BIS said.

Comments in response to the notice should include a quantitative and qualitative assessment of the CWC’s impact on commercial activities involving the proposed Schedule 1 chemical families, BIS said.

Comments must be received by September 13, BIS said.

Brian Bradley

Based in Washington, D.C., Brian covers international trade policy for American Shipper and FreightWaves. In the past, he covered nuclear defense, environmental cleanup, crime, sports, and trade at various industry and local publications.