It takes only two milligrams of fentanyl, an amount that can fit on the tip of a pencil, to kill an adult, according to the US Drug Enforcement Administration (DEA). Fifty times more potent than heroin and 100 times more potent than morphine, fentanyl has become the leading cause of accidental death among Americans aged 18 to 44. The scale of the crisis is reflected in the US Centers for Disease Control and Prevention’s July release, which noted that “approximately 69% of all overdose deaths involved synthetic opioids, overwhelmingly illicitly made fentanyl and its analogues”.As US cracks down on illicit fentanyl use, the ripples have reached the distant shores of India’s western coast. Enforcement action has extended to entities linked to the chemicals and pharmaceuticals hub of Surat, with India being seen as filling a supply void created by China’s strict ban on the key ingredients that go into fentanyl production.Yet fentanyl itself is not an illicit drug. Legally manufactured fentanyl is essential to modern medicine, with uses ranging from severe pain management and cancer care to anaesthesia and trauma treatment. It is tightly controlled in the US and regulated under the Narcotic Drugs and Psychotropic Substances Act in India. India’s regulatory framework, however, has been exploited by illicit actors sourcing chemicals for fentanyl production.
The Surat files
A Gujarat Anti-Terrorist Squad’s case from 2025 centres on Satishkumar Sutaria of Surat-based Athos Chemicals. Investigators allege that Sutaria and associate Yukta Modi, now out on bail, forged end-user certificates — the mandatory declarations designed to ensure dual-use chemicals reach legitimate buyers — to obtain huge quantities of chemicals that go into to the making of fentanyl.According to investigators, chemicals like N-Boc-4-piperidone, 4-Anilino-N-phenethylpiperidine (ANPP), and N-Phenethyl-4-piperidone were routed to J&C Import, a Guatemalan company allegedly linked to Mexican drug trafficking cartel Sinaloa intermediary Jaime Augusto Barrientos Camaz. One kilogram of N-Boc-4-piperidone can yield about 1.8kg of fentanyl, enough for about 9 lakh lethal doses. Sutaria and Modi are accused of facilitating, among other things, the procurement of 116kg of N-Boc-4-piperidone. This April, the US Treasury Department’s Office of Foreign Assets Control (OFAC) imposed sanctions on Sutaria, Modi, and their associated companies. But the Indian links don’t end there.A US federal case in Brooklyn has implicated another Surat businessman, Bhavesh Lathia of Raxuter Chemicals, who pleaded guilty to distributing and smuggling more than 50 pounds of precursor chemicals. Prosecutors said he brokered sales online and knowingly mislabelled shipments as “Vitamin C” and “antacids” to slip past customs. He faces up to 40 years in prison.For years, Mexican cartels sourced many of its precursor chemicals through China. But, investigators say, procurement networks increasingly turned to India as Beijing tightened controls.Enforcement attention on Gujarat is explained by its position in India’s chemicals trade. The state accounts for roughly 50% of the country’s chemical output across more than 5,000 chemical units. It is also home to around 3,000 pharmaceutical units. Deep-water ports such as Mundra and Pipavav provide direct maritime access to Central America, with India’s roughly $60-billion pharma industry one of the world’s largest such ecosystems.It is this ecosystem that unscrupulous actors have used to drive illegal sales. “Customers may operate through intermediaries, distributors, brokers, or multiple business entities. Documentation may appear complete, yet the actual end-use of a chemical may not always be fully transparent,” said Dr Jaimin Vasa, president of Gujarat Chemical Association. What raises red flags, he added, are “unusually large orders, purchase quantities inconsistent with declared business activities, unusual urgency or unconventional payment arrangements”.The US Intelligence Community’s 2025 Annual Threat Assessment ranks India second only to China as a source of illicit fentanyl precursors and pill-pressing equipment. But the trail is complex. The 2025 annual report of International Narcotics Control Board (INCB) logged four European seizures of 1-Boc-4-piperidone in the second half of 2024, noting that “the substance originated in India”.India responded in Jan 2025, bringing two fentanyl precursors, including 1-Boc-4-piperidone, under stricter control through Narcotic Drugs and Psychotropic Substances Amendment Order, 2025. The payoff was measurable: a coordinated interdiction using INCB’s pre-export notification online system stopped three tonnes of the chemical from reaching illicit channels. The board estimated that the shipment could have produced 1.4 to 3.3 tonnes of fentanyl, or somewhere between 700 million and 1.6 billion potentially lethal doses.
Chinese, Afghan trigger
The geography of the trade changed dramatically on May 1, 2019, when China imposed class-wide controls on finished fentanyl-related substances or analogues.The significance lay in the method. Rather than banning substances one by one, China’s 2019 framework covers any compound that meets defined structural criteria — including variants not yet seen on the market. That closed the traffickers’ oldest workaround: altering the finished fentanyl molecule just enough to produce a potent but unregulated analogue.Shut out at the finished-drug end, syndicates moved further back down the synthesis chain. Rather than modifying the drug, rogue suppliers began modifying precursor building blocks (pre-precursors) such as para-fluoro-Boc-4-AP and ortho-methyl-Boc-4-AP (BOC-X) — chemicals that passed customs screening lawfully while still serving as effective inputs for the production of fentanyl and fentanyl analogues.In mid-2024, China tightened controls further, placing 24 precursor chemicals under export licensing requirements. On July 20, 2025, Beijing brought 4-piperidone and 1-Boc-4-piperidone under strict national control.Did it work? Researchers Chao Wang and Nicholas Lassi of Zhejiang University’s Guanghua Law School argue it displaced the problem rather than dismantling it. In “Combating illicit fentanyl: Will increased Chinese regulation generate a public health crisis in India?”, they trace how sourcing migrated — citing DEA intelligence that syndicates moved precursor procurement from China to India between Feb and March 2018, “likely due in part to China’s regulation of ANPP and NPP”.A second shock reshaped the market at the same time. The Taliban’s ban on opium poppy cultivation drove a 95% collapse in Afghan opium production, according to INCB, pushing demand harder towards synthetics. INCB has since flagged the arrival of nitazenes — opioids up to 30 times more potent than fentanyl, now being sold as “synthetic heroin”.
Regulatory route
Precursor control is where the two Asian giants take different paths. China regulates by chemical class. India regulates by list — naming substances one by one, which means regulators must identify each new compound after traffickers have already begun using it.India has been expanding that list fast. On Jan 23, 2025, the department of revenue added 18 designer compounds under Schedule B and C controls, including 4-piperidone, 1-Boc-4-piperidone. As of June 1, 2026, the national precursor registry covers 46 scheduled substances. Scheduled substances are those whose production and use is tightly controlled to prevent misuse.But the hardest chemicals to control are the ones legitimate industry cannot function without. Aniline and propionyl chloride — both associated with the Gupta synthesis pathway (see box) — are widely used in India’s dye, rubber and textile sectors, and remain unscheduled for that reason.In June 2026, the Narcotics Control Bureau (NCB) responded by introducing a Voluntary Code of Conduct built around a “watch-out list” of 82 high-risk but unscheduled chemicals, including aniline, propionyl chloride and valerophenone.Releasing it in Ahmedabad on June 16, NCB director-general Anurag Garg was candid about the limits of policing: “While enforcement agencies play a critical role in interdiction and investigation, the fight against synthetic drugs cannot be won through enforcement action alone.”
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He said the chemicals industry had a crucial role to play, because those closest to the supply chain are often best placed to spot the early signs of diversion: unusually large or suspicious orders, abnormal purchasing or consumption patterns, and attempts to conceal a chemical’s intended end use.Govt is seeking to strengthen that vigilance with technology. The PREP Portal, introduced under its Vision Document on Drug Control (2026-2029), is designed to track dual-use chemicals through India’s supply chains and flag potential diversion before consignments leave the country.For investigators tracking the trade across continents, the devastation caused by illicit fentanyl is no longer in question. The harder question is whether regulation can keep pace with the chemical supply chains that sustain it. India’s chemical corridors are now central to that challenge.With inputs from Parag Dave
