Introduction

Chemical security and safety is key to protecting civilian populations, national infrastructure, and military assets from both accidental chemical leaks and intentional chemical attacks. The dual-use nature of chemicals—for peaceful, legitimate purposes and to cause harm—makes their management and the crafting of relevant policy a critical concern. Advancements in scientific capabilities and industrial technologies have eased access to potentially hazardous substances, increasing the risk of chemical misuse in acts of sabotage, terrorism, and warfare.

The use of chemical weapons during the First World War resulted in over 100,000 deaths; over a million more deaths after the war were attributed to chemical weapons too.^[1] This calamity led to the signing of the Geneva Protocol (officially, the Protocol for the Prohibition of the Use of Asphyxiating, Poisonous or Other Gases, and of Bacteriological Methods of Warfare) in 1925.^[a],[2] In the subsequent decades, the United Nations (UN) General Assembly also denounced chemical weapons in a series of resolutions, beginning with Resolution 2162 B, adopted in 1966; followed by Resolution 2454 A in 1968; Resolution 2603 B in 1969; and Resolution 2662 in 1970. These resolutions called on all states to strictly adhere to the principles and goals of the Geneva Protocol and denounce any actions that contravene those goals, and invited all states to accede to the Protocol.^[3] Resolution 2603 A (1969), which provides an interpretation of the Protocol, agrees with the condemned nature of chemical weapons and reiterates the ban under the Geneva Protocol.^[4]

While the Geneva Protocol is a crucial measure in banning the use of chemical and biological weapons during war, it has limitations. One issue is that many countries signed the Protocol with reservations, and their implementing domestic regulations thus had loopholes. For instance, some states have retained the right to respond with chemical weapons if they are attacked first with such weapons. This loophole has weakened the taboo of chemical weapon use and the Protocol’s ability to deter aggression, allowing some countries to continue developing chemical weapons.^[5] Moreover, the Protocol only addresses the use of chemical weapons, but does not prevent their development, production, stockpiling, or transfer. This has allowed countries to maintain and expand their arsenals legally, thereby increasing the risk of proliferation and misuse.^[6] Consequently, chemical weapons were used during the Second World War, the Cold War, and in several regional conflicts in the 1970s and 1980s, including Vietnam and South Korea (see Table 1).^[7]

Table 1: Large-Scale and Recorded Use of Chemical Weapons

Era	Chemical Agent	Impact
First World War	Chlorine Gas	Germany used chlorine gas during the Second Battle of Ypres in 1915, which resulted in mass casualties.[8]
	Phosgene Gas	Phosgene was introduced by Germany in 1915.[9]
	Mustard Gas	Mustard gas caused severe blistering, lung damage, and long-term disabilities.[10]
Second World War	Mustard Gas	Germany and Japan developed and stockpiled chemical agents like mustard gas, but their use was limited in combat.[11]
	Nerve Agents (Tabun)	Nazi Germany secretly developed and tested nerve agents like Tabun on prisoners in concentration camps, enabling the emergence of post-war chemical weapons.[12]
Korean War	Toxic Industrial Chemicals	The US allegedly used chemical weapons, such as napalm and tear gas, against North Korean and Chinese forces.[13],[14]
Vietnam War	Agent Orange	The US used Agent Orange in Vietnam, causing widespread health issues and environmental damage due to its dioxin content.[15]
Gulf War	Mustard Gas, Nerve Agents	Iraqi forces were reported to have used chemical weapons, such as mustard gas and nerve agents, against Kurdish civilians in the Haljaba Massacre.[16]
Other Instances (until 2000)	Sarin	The Aum Shinrikyo cult in Japan released sarin gas in the Tokyo subway in 1995, killing 13 and injuring over 1,000.[b],[17]
	Sarin, VX, Chlorine Gas	The Assad regime allegedly used chemical weapons, such as sarin gas, during the civil war in Syria.[18] The various warring factions in Syria have also allegedly used chlorine gas.[19]

Source: Author’s own, using various open sources.

In 1992, 157 countries  signed the Chemical Weapons Convention (CWC),^[c] to be implemented by the Organisation for the Prohibition of Chemical Weapons (OPCW).^[20] Following the formation of the OPCW, the UN Security Council also signed Resolution 1540, which prohibits (a) the proliferation of weapons of mass destruction (WMDs), including chemical weapons, and (b) providing support to non-state actors “that attempt to develop, acquire, manufacture, possess, transport, transfer or use nuclear, chemical or biological weapons and their means of delivery, in particular for terrorist purposes.”^[21]

Despite efforts to restrict the proliferation and use of chemical weapons, they continue to be used in conflicts worldwide.  The use of such weapons in the conflicts in Syria, Iraq, and the Iran-Iraq War highlights the gaps in the enforcement of international law.

Comprehensive strategies, including risk assessments, inventory controls, and information sharing, are crucial for effectively managing chemical risks. The development of synthetic toxins, artificial intelligence (AI), and the emergence of online chemical marketplaces present new vulnerabilities and challenges for regulators. International frameworks such as the CWC, national-level regulations, and participation in external and voluntary audits can form a multi-layered defence system to address these multifaceted challenges. However, such guidelines, treaties, and regulations need to be updated to reflect the changing markets and technologies that impact chemical compositions and the access to chemicals.

Chemical Weapons in Conflict Scenarios

Chemical weapons have historically been used in conflicts to achieve strategic goals. In the last 25 years, chemical weapons have resurfaced in many conflicts, despite the CWC. The Bashar al-Assad regime allegedly used chemical weapons against civilian populations amid the civil war, violating both national and international law and despite Syria’s accession to the CWC in 2013. Indeed, the use of these weapons in Syria raised concerns about the OPCW and the UN’s ability to enforce compliance and curb the development and use of chemical weapons in active conflict zones.^[22] Notably, following the fall of the Assad regime, Syria has vowed to eliminate its chemical weapon stockpile.^[23]

There are concerns that Iran may pursue, if it is not already in possession of chemical weapons despite signing the CWC. Iran allegedly invested in the development of chemical weapons after the use of such weapons against it during the Iran-Iraq War.^[24] The US has routinely accused Iran of developing and stockpiling chemical weapons,^[25] and there are fears that Iran's regional influence (particularly through proxy groups such as Hezbollah and the Houthis) could amplify the threat of chemical weapons being used indirectly in West Asian conflicts.^[26]

The Israeli security forces and police frequently use riot control agents (RCAs)^[d] in the occupied Palestinian territories, particularly following the escalation of protests and military operations since the early 2000s. The Israel Defense Forces (IDF) and border police have deployed tear gas and skunk water^[e] against Palestinian civilians during protests or even routine patrols, especially in the West Bank since 2008.^[27],[28] While the CWC allows the use of RCAs for law enforcement, Israel deploys these agents in militarised environments that violate international humanitarian norms.^[f] The IDF has also employed white phosphorus in civilian regions.^[g],[29]

Russia has also allegedly used chemical weapons in the attempted assassination of former military agent Sergei Skripal.^[30] While the OPCW reported that Russia’s entire stockpile of chemical weapons was destroyed in 2017, the US has claimed the stockpile was underreported and that Russia has used RCAs against Ukraine.^[31] Russia's use of pharmaceutical-based agents (PBAs)^[h] and RCAs raises concerns under international law, in addition to the use of nerve agents like Novichok, and supposed undeclared stockpiles. Russian special forces used the PBA carfentanil, a potent synthetic fentanyl-based opioid, during the 2002 Moscow theatre hostage crisis that resulted in the deaths of over 100 hostages.^[32] Russia has also allegedly utilised RCAs such as tear gas and similar agents against civilian populations and resistance groups in Ukraine, especially in areas that are under occupation or are experiencing active conflict.^[33]

Similarly, North Korea has been accused of stockpiling chemical weapons, with South Korea claiming the country has between 2,500-5,000 tons of chemical weapons, including mustard, phosgene, Sarin, and VX.^[34] North Korea’s lack of openness is concerning and indicative of its approach to deterrence, intimidation, and asymmetric warfare, particularly when conventional military capabilities are limited.

India, for its part, had a stockpile of 1,044 metric tons of chemical weapons in 1997 and had fully destroyed the stockpile by 2009.^[35] For India and Southeast Asia, the existence of chemical weapons in neighbouring regions, including the risk posed by rogue states, presents security concerns. India’s proximity to the volatile Middle East and the ongoing tensions in Pakistan and Afghanistan aggravate the threat; as does the country’s proximity to Myanmar. Myanmar’s military has faced multiple accusations of using chemical weapons against ethnic armed groups and resistance forces, especially since the 2021 military coup.^[36] These attacks have reportedly involved the use of chemical agents such as ‘yellow vapour’ and phosphine gas from aluminium phosphide canisters.

Despite decades of international legal frameworks and active disarmament efforts, chemical weapons continue to be used in asymmetric warfare and authoritarian conflicts as they offer a cost-effective means of achieving tactical benefits. The relative ease of producing chemical agents from dual-use industrial chemicals, especially in poorly regulated areas, has enabled both state and non-state actors to circumvent formal restrictions. The ability of threat actors like terror groups and radicalised individuals to access PBAs and RCAs is a CWC loophole that needs consideration. Enforcement mechanisms under existing treaties such as the CWC are often weakened by limited access in active war zones, political pushback, and the ambiguous nature of dual-use technologies and chemicals.

The Use of Chemical Weapons in Acts of Terrorism

Terrorist organisations and threat actors have employed chemical weapons to inflict damage, cause mass casualties, and provoke political instability. Groups such as the Islamic State have demonstrated an interest in acquiring, producing, and potentially deploying chemical agents for terror purposes.^[37] The use of chemical weapons for terror attacks can be traced to 1999, when militant jihadist Abu Mus’ab al-Zarqawi showed an intent to weaponise toxins in Iraq. US forces uncovered multiple labs over the years in Khurmul, Fallujah, and Mosul, confirming efforts to build rudimentary chemical improvised explosive devices (IEDs).^[38] In 2004, al-Zarqawi’s network plotted a massive chemical attack in Amman, Jordan, involving 20 tons of industrial chemicals aimed at creating a toxic cloud over the city. Chlorine was later used in vehicle-borne improvised explosive device attacks across Anbar province in 2006 and 2007, though with limited physical effect.

After a lull, the Islamic State revived the use of chemical weapons in terror attacks in 2013, capitalising on the chaos in Iraq and Syria. It used territorial control and access to chemical-rich facilities, such as those near Mosul, to build makeshift labs and attract foreign technicians and former Iraqi regime scientists.^[39] Its use of chlorine and low-grade sulfur mustard, sourced from fertiliser plants, sulfur mines, and water treatment facilities, reflected both a lack of access to high-grade agents and limited scientific expertise.^[40] The group’s use of chemical agents like sulfur mustard in Iraq and Syria showcased the threat that non-state actors can pose with access to chemical weapon precursors and rudimentary delivery methods.

The al-Qaeda network has also historically shown an interest in chemical weapons. However, while the group has allegedly tested cyanide on animals, it has not been recorded using chemical weapons or any WMD.^[41] Although it is yet to deploy them on a large scale, the group has been involved in efforts to acquire chemical weapon precursors and has sought to develop a chemical warfare capability.^[42]

There remains a persistent threat of terrorism involving chemical agents. Homegrown terrorists, particularly those operating in areas with weak governance structures, may gain access to precursor chemicals through illicit means. The increasing sophistication of terrorist organisations in accessing dual-use technologies, including growing biotechnology and the production of chemical weapons, has made this threat increasingly difficult to monitor.^[43]

In India and Southeast Asia, the threat of terrorism using chemical weapons is of particular concern due to the presence of active terrorist groups such as Lashkar-e-Taiba (LeT) and Jaish-e-Mohammed, and the growing influence of Islamic State-affiliated cells in the region. These groups, particularly in conflict-prone regions like Kashmir, India’s Northeast, and parts of Pakistan, could exploit vulnerabilities in industrial regulations or illicit chemical trade routes to pursue chemical attacks.

In response, India has regularly updated the SCOMET list^[i] to place restrictions on precursor sales and monitors sensitive infrastructure.^[44] However, challenges persist, including the poor tracking of chemical inventories at private facilities, gaps in intelligence sharing between state and central agencies, and a lack of awareness among smaller businesses. A stronger audit system, improved real-time data sharing, and better cooperation between the public and private sectors are necessary to secure the chemical supply chain against future threats.

The Availability of Chemical Precursors

Many chemicals that can be weaponised are easily accessible, often in higher quantities than needed for legitimate industrial purposes. These are referred to as toxic industrial chemicals (TICs) or precursors, as listed in the CWC schedules.^[j] For instance, ammonium nitrate, which has legitimate industrial and agricultural purposes and has also been used in cases of domestic terrorism in India (see the next section for instances of use),^[45] is often available in quantities far exceeding immediate industrial need, making its diversion difficult to monitor and control.

Chlorine is widely used for water treatment and in the manufacture of cleaning agents, plastics, and other chemicals. It is widely stored in large quantities in tanks, which could become a weapon of mass destruction if attacked or mishandled. Chlorine gas, released into the environment, directly and dramatically affects the respiratory system, with high concentrations potentially leading to death.^[46]

Similarly, phosphorus compounds used in the production of fertilisers and pesticides can be converted into chemical agents that cause burning and blistering in targets. White phosphorus is often used to diminish visibility in conflict areas, but if ingested or inhaled, it can lead to issues with visibility and breathing, as well as burning.^[47] Although such substances are highly regulated, their widespread use in civilian areas makes it much more challenging to trace and control their quantities.

The easy availability of TICs, such as ammonium nitrate and chlorine, complicates the chemical security landscape. Notably, several other countries still lack the financial and technical capabilities to effectively monitor the production, trade, and transport of such hazardous substances. Emerging technologies further complicate the defence landscape. The advent of machine learning, which can generate information on precursor chemicals and TICs, PBAs, or dual-use chemical synthesis tools, has expanded the threat horizon by allowing for the relatively easy creation of weaponisable compounds.

The threat landscape is not limited to traditional state actors. The CWC divides chemicals into three sub-sections based on risk and use in industrial and agricultural settings. Schedule 1 chemicals are the most toxic and possess the biggest risk for chemical weapons use. These include toxic chemicals such as sarin, VX nerve agents, and mustard gas, as well as precursors and chemicals that can be easily converted into weapons-grade materials.^[48]  Schedule 2 and Schedule 3 chemicals are also under control but are more frequently used in civilian applications (such as the agricultural and pharmaceutical industries).^[49],[50] These materials present a less immediate threat than Schedule 1 chemicals, but could still be diverted for military applications.

International control regimes, such as the Australia Group, which seeks to standardise the export controls of chemical substances and their precursors, are essential to monitoring the transfer of dual-use substances. However, these regimes are voluntary and not universally applied. Additionally, countries with limited financial or forensic capacity face challenges in enforcing reporting obligations, monitoring domestic stockpiles, or tracking surveillance on digital supply chains for chemicals.

Emerging technologies such as Machine Learning pose additional challenges to regulation, but can also offer partial solutions. Open-source AI models (including chemical synthesis software) and dark web forums can allow malicious actors to develop or repurpose precursors without having formal training as lab technicians. For countries like India, which have a large and growing industrial footprint and a goodwill effort, there is an opportunity to improve chemical security infrastructure to support its expanding technology capacity. This effort will not only address emerging vulnerabilities but also provide the opportunity to modernise and harness the capacity presented by dual-use technology.

The potential use of TICs, including those in precursor processes for Schedule 1, Schedule 2, and Schedule 3 chemicals, by non-state actors, such as terrorist groups, has made chemical security a matter of both domestic and international defence. Although the CWC imposes constraints on the manufacture, storage, and use of these compounds, many of the Schedule 1 chemicals are produced by industrial processes. They are applied in water treatment, production, agriculture, and medicine. Due to their dual-use nature, they are susceptible to diversion by bad actors. Currently, the use of RCAs or PBAs has been limited in the Indian threat landscape. However, with a concerning neighbourhood and recurring terror threats, this could be the next step for threat actors, but can be deterred through regulatory steps and access barriers.

India’s Approach to Chemical Safety and Security

Chemical weapons pose a unique challenge to India’s national security. Unlike conventional weapons, chemical agents can be deployed covertly and cause indiscriminate harm to civilians, disrupting daily life and overwhelming first responders. The Bhopal gas tragedy of 1984, a result of industrial negligence, highlights the vulnerability of civilians to chemical disasters and underscores the importance of stringent regulations, oversight, and disaster management planning for handling hazardous chemicals.

To build a more precise understanding of domestic chemical threats, it is necessary to distinguish between the use of chemical toxins (typically Schedule 1 agents, such as sarin or VX, intended for mass poisoning) and chemical enhancers (such as ammonium nitrate or chemical timers used to increase the lethality or precision of IEDs). While the former remains a hypothetical threat in India due to strict controls, the latter is already part of the operating toolkit of domestic terrorist groups.

Non-state actors like LeT and the Indian Mujahideen (IM) have repeatedly chosen chemical enhancers to enhance the impact of their attacks, rather than relying on strategic chemical attacks, driven by goals such as high civilian casualties, symbolic targeting of religious sites or urban centres, and timed detonation for maximum disruption. These actors rarely aim for widespread contamination; instead, the intention appears to be to weaponise industrial or agricultural chemicals to enhance explosive yield or timing. The CWC's tripartite schedule system^[k] is relevant in this context, as even Schedule 2 and Schedule 3 substances, normally used in fertiliser or pharmaceutical manufacturing, can be diverted to serve such ends.

Domestic security threats involving chemical agents may arise from terrorist groups, criminal organisations, or even rogue individuals. The threat of chemical attacks on critical infrastructure, including water supply, energy plants, and transport networks, adds another layer of complexity to national security strategies. India has seen several instances of chemical enhancers being used in domestic terrorist attacks:

• 2006 Mumbai train blasts: The LeT and the Harkat-ul-Jihadi Islami used pressure cookers packed with TNT, RDX, and ammonium nitrate.^[51],[52] The attacks resulted in the deaths of 187 individuals and injuries to over 900.^[53]
• 2008 Delhi bombings: The IM planted a series of IEDs in crowded markets across the city. The devices were constructed using ammonium nitrate.^[54] The coordinated blasts caused 24 deaths and injured over 90.^[55]
• 2011 Mumbai bombings: The IM conducted three coordinated blasts using IEDs packed with ammonium nitrate and small metal bearings, resulting in the deaths of 21 people and injuries to 113 others.^[56]
• 2013 Bodh Gaya blasts: The IM targeted the Mahabodhi Temple complex, a revered Buddhist site,^[57] using IEDs packed with ammonium nitrate and ball bearings, along with chemical-based timers for delayed detonation.^[58] Three undetonated bombs were also found at the site.^[59] Though the blasts caused limited physical damage and no deaths, they held symbolic and psychological value as the site is a UNESCO World Heritage landmark.

Current Rules on Chemical Weapons 

India is party to the key global treaties and guidelines, and has also enacted rules domestically to limit chemical weapon use and terrorism (see Table 2).

Table 2: India’s Stance on International Guidelines and Its Domestic Regulations on Chemical Weapons

Category	Year	Description/Impact	Gaps/Challenges
International Guidelines with Relevance to India
Chemical Weapons Convention[60]	1993 (Adopted), 1997 (Enforced)	Multilateral treaty banning the development, stockpiling, and use of chemical weapons. India is a state party.	Difficult to enforce, relies on countries’ self-reporting. Dual-use chemical control remains difficult.
Organisation for the Prohibition of Chemical Weapons[61]	Operational from 1997	Monitors CWC implementation; India cooperates and submits declarations.	Limited capacity for intrusive verification; relies on national reporting accuracy. Has often reported on chemical stockpiles being dismantled (as was the case with Russia and Syria) by various countries, but reports by several countries disagree with such findings.
Australia Group[62]	1985 (formed)	An informal export control regime aimed at preventing the spread of chemical and biological weapons by harmonising export controls among participating countries. India joined in 2018.	Challenges include balancing export controls with industrial and scientific development, as well as ensuring compliance across various sectors.
Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal[63]	1989 (Adopted), 1992 (Enforced)	Regulates the international movement of hazardous waste to protect human health and the environment. India is a party.	Enforcement challenges emerging from illegal waste shipments and a lack of capacity in developing nations.
Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade[64]	1998 (Adopted), 2004 (Enforced)	Promotes shared responsibilities in the import and export of hazardous chemicals and pesticides. India is a party.	Relies heavily on information exchange and national governments enforcing implementation.
UN Security Council Resolution 1540[65]	2004	Obligates states to prevent the proliferation of WMDs, including chemical weapons, via national legislation.	Verification and enforcement challenges mirror the CWC.
Indian Regulations to Curb Chemical Weapons and IEDs
Manufacture, Storage and Import of Hazardous Chemicals Rules, 1989[66]	1989	Established under the Environmental Protection Act, 1986.[67] Governs the manufacture, storage, and handling of hazardous substances.	Weak enforcement in small and medium-sized enterprises.   Chlorine and phosphorus are regulated under hazardous chemical lists; safety norms exist for industrial handling, but there are no specific guidelines for curbing malicious use.
Chemical Weapons Convention Act, 2005[68]	2005	India’s domestic law aligns with the CWC and bans the development and use of CWs. Also established the National Authority for Chemical Weapons Convention.	Implementation gaps in industrial surveillance and low public awareness. Does not consider weaponisation of TICs.
The Weapons of Mass Destruction and their Delivery Systems (Prohibition) Act, 2005[69]	2005	Prohibits the development and delivery systems for WMDs, complementing CWC obligations.	Enforcement mechanisms require regular updates, a focus on public awareness, and collaboration between different security agencies.
Disaster Management Act, 2005[70]	2005	Provides a framework for managing disasters, including chemical attacks.	Lacks chemical warfare-specific emergency planning.
Explosives Act, 1884[71]	1884	Regulates the manufacture, possession, use, transport, and trade of explosives, including definitions and offences.	Not designed for industrial dual-use chemicals; needs modernisation.
Indian Regulations Focusing on Ammonium Nitrate
Ammonium Nitrate Rules, 2012 (as amended)[72]	2012	Regulates the entire lifecycle of ammonium nitrate (manufacture, transport, storage, sale).	Enforcement depends on state-level capabilities; monitoring transport routes remains weak.
Notification S.O. 1678(E), 2011[73]	2011	Declares ammonium nitrate a deemed explosive under Section 17 of the Explosives Act	While helpful, it does not address stockpile traceability or the risks of large-volume agricultural diversion.
Manufacture, Storage, and Import of Hazardous Chemicals Rules, 1989[74]	1989	Lists ammonium nitrate as a hazardous chemical; regulates its import and storage.	The focus is primarily on industrial safety, and not national security risks from deliberate misuse.
DGFT Notification No. 34 (RE-2013), dated 14.08.2013[75]	2013	Requires prior permission for the import of specific ammonium nitrate grades.	Does not apply to domestic production, which forms the bulk of ammonium nitrate used for illicit IEDs.
CBEC Instruction F.No. 450/37/2014-Cus IV[76]	2014	Directs Customs to enforce the Ammonium Nitrate Rules, 2012, at points of import.	Customs' focus is limited to border control; it lacks integration with inland enforcement mechanisms.

Source: Author’s own, using various open sources. 

India’s approach to chemical security involves multiple agencies and ministries, including the Ministry of Home Affairs, Ministry of Environment, Forest and Climate Change, Directorate General of Foreign Trade, Department of Chemicals and Petrochemicals, National Association for Chemical Security (NACS), and National Authority for Chemical Weapons Convention (NACWC), with the latter two being the primary responsible. However, overlapping mandates, siloed data systems, and limited inter-agency coordination hinder proactive monitoring and response.^[77] Furthermore, implementation often depends on the state governments, which lack adequate technical training or resources to track dual-use chemicals effectively. These administrative gaps, combined with the sheer scale of India’s industrial and agricultural sectors, make it challenging to maintain comprehensive oversight of chemical security, particularly in rural or semi-regulated regions where diversion risks are highest. 

In addition to the central regulations, several Indian states have formulated policies and institutional mechanisms for chemical safety and security within their jurisdictions (see Table 3).

Table 3: State-Level Chemical Security Measures

State	Key Institutions	Activities
Maharashtra	State Disaster Management Authority[78]	Manages hazardous chemical storage, transport, and emergency response Conducts risk assessments and emergency drills.
Tamil Nadu	Special Disaster Response Force (CBRN-trained unit) Chemical Safety and Security Task Force[79]	Chemical, biological, radiological, and nuclear emergency preparedness. Enforces Chemical Weapons Convention Act, 2005, and Explosives Act, 1884.
Andhra Pradesh	Andhra Pradesh Pollution Control Board, District Collectorates (post-2020 Visakhapatnam gas leak reforms)[80]	Emergency protocols for chemical industries. Port area surveillance.
Odisha	Odisha State Disaster Management Authority, State Pollution Control Board[81]	Industrial zone risk mapping. Chemical safety enforcement in Paradeep and Angul.[82]
Delhi NCR / Haryana	Delhi Disaster Management Authority, Haryana Dept of Industries.[83],[84]	Oversight in chemical handling units. Emergency drills in urban-industrial zones.

Source: Author’s own, using various open sources.

Note: The state regulations listed explicitly mention chemical disasters, albeit in the context of chemical safety and trade, and focus on disaster management rather than security. Other states resort to the central and state-level pollution control boards to monitor chemical leaks and disasters.

The state initiatives demonstrate localised implementations of national templates tailored to accommodate industrial contexts and varying risk profiles. Despite this, efforts are hindered by resource limitations, non-uniform enforcement, and limited data exchange among states and central agencies. Enhanced capacity-building programmes, expanded technical training for inspectors, and the integration of real-time monitoring tools are crucial to boost the state-level contributions to India's overall chemical security.

Global Approaches to Chemical Security and Takeaways for India

India can learn from two instances of advanced approaches to chemical security: those of the US and the European Union (EU), particularly in initiatives led by Switzerland.

In the US, the Chemical Facility Anti-Terrorism Standards (CFATS) programme, administered by the Department of Homeland Security, is notable.^[85] The CFATS requires high-risk chemical facilities to identify security vulnerabilities and implement site-specific security plans. India can adopt a similar approach, classifying chemical facilities by threat level and prioritising oversight accordingly. This will allow regulators to focus resources on high-risk locations and track suspicious large orders that may be decoys by non-state threats.

In the EU, chemical safety is regulated through two flagship policies. The REACH regulation^[l]  governs chemical production and use,^[86] while the Seveso III Directive^[m] focuses on preventing and controlling industrial accidents involving hazardous substances.^[87] These regulations compel companies to assess chemical risks comprehensively and maintain transparency throughout the supply chain, limiting non-state actors from using industrial purchases as a cover for the malicious use of TICs and precursor chemicals. Additionally, as part of its ‘science diplomacy’ initiative and strategy for arms control and disarmament, Switzerland has initiated the Spiez CONVERGENCE conference series to evaluate the implications of scientific advancements, including DNA editing, machine learning, and the use of non-canonical amino acid technology for toxin production.^[88] India can adopt similar mandates that require industries to disclose comprehensive risk profiles, maintain up-to-date risk and safety databases, and collaborate with local authorities in emergency planning. This will enhance transparency and supply chain accountability. India must also participate in conferences like Spiez CONVERGENCE to ensure the conversation addresses local threats and advances its goals as well.

Interpol plays a critical role in global chemical security by facilitating international cooperation among law enforcement agencies to prevent the misuse of chemicals for criminal and terrorist purposes. Through its Chemical and Explosives Terrorism Prevention Program, member countries enhance capabilities in detecting, investigating, and prosecuting chemical-related crimes, including the illicit trafficking of toxic industrial chemicals and precursors that could be weaponised.^[89] Interpol coordinates intelligence sharing, issues alerts and warnings about chemical threats, and supports capacity-building through specialised training and workshops on best practices in chemical security. Additionally, Interpol fosters collaboration through its task forces and partnerships focused on chemical, biological, radiological, and nuclear weapons and non-proliferation.^[90] By operating as a global platform for information exchange, operational support, and technical assistance, it increases barriers for non-state actors to exploit chemical substances for terrorist or criminal activities.

While international frameworks such as the CWC and the Basel and Rotterdam Conventions provide a robust legal architecture, their implementation often suffers from uneven compliance, opaque reporting by some states, and limited enforcement capacity. This weakens global deterrence against chemical weapon misuse, especially when key actors exploit verification loopholes or strategically underreport chemical inventories. For India, whose neighbourhood includes both state and non-state threats with histories of chemical misuse, the lack of global enforcement increases vulnerability. A stronger international monitoring regime, complemented by regional cooperation and technology transfer, will provide India and other nations in the Global South with the capacity to track and manage chemical threats in real-time.

Policy Recommendations for India

Despite international frameworks such as the CWC, export control regimes like the Australia Group, and India’s regulatory tools to address chemical security and safety, the country faces domestic challenges in chemical security. The growing threat of domestic terrorism, particularly involving IEDs and TICs, underscores the need to upgrade the approach. The following recommendations pertain to the NACWC and NACS to ensure India’s chemical security evolves to include TICs.

• Proactive Inspections and Risk-Based Licensing: Many chemical facilities, particularly small and medium enterprises, operate with minimal oversight. Inspections are infrequent and typically reactive, increasing the risk of diversion for malicious purposes. Similar to the US’s CFASTS, the NACWC should establish a risk-tiered licensing and inspection regime, with a priority focus on facilities handling dual-use and precursor chemicals, certifying them regularly and repeatedly, based on surprise inspections and supply chain transparency. Regular third-party audits and certifications should also be encouraged. This will also include training inspectors to understand chemical security and the impact of technology on chemical security and risks.
• Real-Time Chemical Inventory and Movement Tracking: India lacks a unified, real-time system to track the production, storage, and movement of hazardous chemicals. This impedes emergency response and allows stockpiling or diversion for IED manufacturing. This will include accelerated alignment with REACH, enforcing and requiring registration of all chemical handlers, including transporters and warehouses, and utilising GPS-enabled tracking for PBAs, TICs, and precursor chemicals bought in high-risk amounts. This will also address international trade and monitoring, if implemented at the ports.
• Oversight of Dual-Use Research and Synthetic Biology: Advances in biotechnology and synthetic chemistry pose dual-use risks. Open-source tools for DNA synthesis or compound design can be misused to create chemical agents. India must participate in global conversations on the impact of emerging technologies on chemical weapons and ensure the regular assessment of such emerging technologies to limit the use of chemicals by non-state actors. India must also focus on cybersecurity to restrict access to the dark web for chemical components and safeguard chemical infrastructure databases.

Conclusion

The evolution of chemical weapons from state-sponsored arsenals to tools accessible by non-state actors marks a troubling shift in the global security landscape. Historically associated with large-scale warfare, chemical agents are now embedded in asymmetric and irregular conflicts, where access to dual-use industrial chemicals enables smaller actors to inflict disproportionate harm. India faces a unique and pressing threat in this regard. While it has never employed chemical weapons in warfare, it remains vulnerable to the domestic misuse of PBAs, TICs, and precursor materials, such as ammonium nitrate, chlorine, and phosphorus compounds. The increasing frequency of ammonium nitrate-enhanced IEDs in domestic terror incidents underscores how easily available industrial chemicals can be weaponised in the absence of strict controls and real-time monitoring.

Strengthening its chemical security regime will not only address India’s immediate threat of domestic terrorism using IEDs and TICs, but also fortify its global standing as a responsible chemical power. Through strategic foresight, institutional reform, and international cooperation, India can effectively safeguard its population, infrastructure, and economy against an insidious form of modern asymmetric warfare.

Endnotes

• International Affairs
• India
• chemical precursors
• chemical weapons convention
• chemical weapons terrorism
• dual use chemicals
• dual use chemicals security
• dual use chemicals threats
• dual use industrial chemicals
• toxic industrial chemicals

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