The recent conventional targeting of chemical infrastructure in Iran and the resulting toxic releases expose a gap in the Chemical Weapons Convention (PDF), or CWC, that has become increasingly apparent in recent years.
Israeli attacks on Iranian petrochemical and energy facilities, part of a wider US-Israel military campaign against Iran, have released a significant amount of chemicals into the air, including nitrogen oxides, sulfur compounds, and other harmful substances, across populated areas. In retaliation, Iran has attacked petrochemical infrastructure across the United Arab Emirates, Kuwait, Abu Dhabi, and Bahrain.
Attacks on chemical facilities have also been evident during the Russia-Ukraine war as well as during the Syrian civil war some years ago, without any legal consequences.
These attacks, and their environmental and human impacts, raise difficult legal and policy questions. Although the CWC prohibits chemical warfare, it remains silent on the chemical releases caused by conventional strikes. We need greater scrutiny of the global chemical-nonproliferation regime to address this gap.
The CWC’s primary objective is to prevent the development, production, acquisition, stockpiling, and use of chemical weapons and their precursors. The treaty operates under the “general-purpose principle,” meaning it bans any chemical used as a weapon, regardless of whether that chemical appears on a specific list. It also maintains broad lists of high-risk chemicals and their ingredients, which are monitored by the Organisation for the Prohibition of Chemical Weapons (OPCW), which implements the CWC. This flexible approach allows the treaty to keep pace with advances in chemical science.
The OPCW ensures compliance through verification and inspection of chemical-weapon stockpiles, production facilities, and industrial sites that handle sensitive chemicals but overlooks the security of industrial chemical infrastructure during armed conflicts. This omission leaves these large-scale repositories of hazardous chemicals vulnerable to conventional attacks. As a result, toxic agents can be dispersed in uncontrolled ways, creating severe health implications and complicating any emergency response.
The problem with the CWC is its criteria for determining what constitutes a chemical attack, where “intent” serves as the guiding principle. In other words, the CWC prohibits toxic chemicals in warfare, and under Article II of the CWC, whether something counts as a chemical weapon and is therefore banned depends on the intent or purpose behind its use.
In practice, when military commanders target a chemical facility, they likely anticipate the release of toxic substances. But such a foreseeable toxic release may not violate the CWC because the strike is directed at infrastructure rather than employing chemicals as a method of warfare. Such actions, however, could still violate state obligations under international humanitarian law regarding excessive civilian harm.
Addressing the attacks on industrial chemical facilities does not necessarily demand a rewrite of the CWC. The existing framework can be refined to help mitigate the release of chemicals. This refinement could include clarifying how the principle of intent applies to foreseeable toxic releases and expanding the role of the OPCW to monitor, document, and assess the impacts of attacks on high-risk chemical infrastructure. It could also involve closer alignment with international humanitarian law to ensure more-consistent evaluation of civilian harm resulting from such incidents.
As part of any efforts to address the impacts of attacks on chemical facilities, states should maintain updated inventories of high-risk chemical sites and share them with relevant international bodies, including the OPCW, especially where facilities could release large amounts of toxic substances if damaged. States should also strengthen safeguards by enforcing stricter safety measures at these sites, including secure storage, secondary containment, and emergency shutdown systems to limit chemical releases during accidents or attacks. States should also engage in regular dialogue to develop a shared understanding of how to assess such incidents under existing legal frameworks, improve the consistency of responses, and strengthen the process for assessing toxic releases in conflict zones.
For the global chemistry community, now is the moment to take decisive action. A comprehensive analysis of toxic-agent behavior during fires caused by attacks on chemical facilities is crucial for understanding how hazardous chemicals disperse and affect nearby populations. Such research must directly inform effective model dispersion patterns and accurate calculation of chemical exposure levels from these toxic releases. It requires mobilization of chemical-industry professionals to actively highlight the ethical and normative dimensions of modern warfare and press for stronger safeguards against targeting industrial chemical facilities in conflict. Governments and international bodies, including the United Nations and the OPCW, should use this evidence to develop clearer guidelines and coordinated responses to chemical releases resulting from attacks on industrial sites, ensuring more-consistent protection of civilian populations and chemical infrastructure.
Anam Murad Khan Credit:
Courtesy of Anam Murad Khan
The CWC’s failure to clearly address toxic-chemical releases caused by conventional strikes on industrial facilities carries serious implications for chemical nonproliferation. But the CWC also has a standard of shared norms evident through its universal adherence. This broad consensus creates an opportunity for states to collectively develop clearer interpretations and practical measures to address the risks posed by attacks on chemical infrastructure. Harnessing this shared commitment will be key to strengthening protections and ensuring that the convention remains responsive to the realities of modern conflict.
Anam Murad Khan is a research associate at the Center for International Strategic Studies in Islamabad.
Views expressed are those of the author and not necessarily those of C&EN or ACS.
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