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While the situation is fluid, and with Trump sending ambiguous signals over the conflict\u2019s endgame, it would be prudent to take stock of what is known and not known about the types and locations of dual-use chemical and biological materials of concern that may be present in Iran. Only then can policymakers make considered decisions about the relative benefits and costs of seeking them out or waiting for a good opportunity to look for them\u2014and what to do if any are ultimately discovered.<\/p>\n
Materials of concern<\/strong>. Following the 8-year-long war between Iran and Iraq, during which\u00a0Iraq used mustard gas, tear gas, and tabun<\/a>\u00a0to devastating effect, Iran admitted to having developed a limited chemical weapons capability, but claimed not to have\u00a0weaponized, stockpiled, or used\u00a0<\/a>any chemical weapons agent.<\/p>\n During the war, declassified US\u00a0intelligence<\/a>\u00a0reports<\/a>\u00a0assess that Iran produced, weaponized, used, and stockpiled some combination of blood, blister, and choking chemical warfare agents. These included\u00a0CS<\/a>, a riot control agent,\u00a0mustard<\/a>\u00a0gas, and\u00a0phosgene<\/a>, as well as possibly\u00a0cyanide<\/a>\u00a0and\u00a0nitrogen mustard<\/a>. When the United States invaded Iran\u2019s one-time adversary during that war, Iraq, in 2003, US troops found\u00a0classified Iraqi correspondence<\/a>\u00a0about Iranian CW use during the 1980s war referencing the same agents as well as the manufacture of\u00a0tabun<\/a>\u00a0and\u00a0sarin<\/a>\u00a0nerve agents.<\/p>\n Iran is a state party to the 1972 Biological Weapons Convention (BWC) and the 1997 Chemical Weapons Convention (CWC). And in 2011, the United States acknowledged that senior Iranian officials publicly\u00a0renounced<\/a>\u00a0the development, production, acquisition, and stockpiling of any weapons of mass destruction.<\/p>\n Starting in 2018, however, US administrations have certified to Congress in annual reports required by law that Iran is not in compliance with\u00a0its chemical weapons treaty obligations<\/a>. And since\u00a02019, a companion report<\/a>\u00a0has consistently expressed \u201cserious concerns\u201d that Iran has \u201cnot abandoned its intention to conduct research and development of biological agents and toxins for offensive purposes.\u201d<\/p>\n Throughout the 1990s and early 2000s, Iran sought to import a range of\u00a0specific dual-use chemicals of concern<\/a>, according to US Treasury sanctions reports, intelligence reports and arms control compliance reports compiled by the Wisconsin Project on Nuclear Arms Control; in addition to legitimate uses, the chemicals can be used in the production of nerve agents such as tabun, sarin, and\u00a0VX<\/a>.<\/p>\n Some potentially concerning activities were not hidden in secret reports but visible in scientific journals.<\/p>\n In recent years, academics aligned with the Islamic Revolutionary Guard Corps (IRGC) and Ministry of Defense have\u00a0published studies<\/a>\u00a0on the pharmaceutical-based agents\u00a0fentanyl<\/a>, a potent synthetic opioid pain-killer, and\u00a0medetomidine<\/a>, a non-opioid veterinary sedative, which have both legitimate medical uses and illicit applications as potential incapacitating or lethal chemical weapons agents.<\/p>\n Iranian military-aligned researchers have also reported\u00a0researching and synthesizing\u00a0<\/a>a very small amount of the Novichok class of nerve agent that Russia used to poison Russian dissident Alexei Navalny in 2020 and retired KGB agent Sergei Skripal and his daughter in Salisbury, England, in 2018. The researchers cited a purpose of helping build up the knowledge base of the Organisation for the Prevention of Chemical Weapons (OPCW), the body that administrates the Chemical Weapons Convention.<\/p>\n Information on Iran\u2019s possible biological materials of concern is sparser than on concerning chemical activities.<\/p>\n The National Council of Resistance of Iran (NCRI), part of an expatriate opposition group once\u00a0designated<\/a>\u00a0by the United States as a terrorist organization but\u00a0de-listed in 2012<\/a>, has\u00a0alleged<\/a>\u00a0that researchers associated with the IRGC and Ministry of Defense conducted research on\u00a0plague<\/a>,\u00a0cholera<\/a>\u00a0and\u00a0anthrax<\/a>, highly pathogenic bacteria well known as biological weapons agents, and aflatoxin, a toxin weaponized by Iraq in the 1990s though\u00a0considered of limited military utility<\/a>. US compliance reports from 2019 to 2023 mention construction of a\u00a0plant for pharmaceutical production of botulinum toxin<\/a>, a deadly neurotoxin widely understood as a\u00a0potential bioweapons agent<\/a>\u00a0due to its high potency at low doses. From\u00a02019 to 2025, the US\u00a0 reports<\/a>\u00a0refer to \u201copen source reports\u201d about [bioweapons]-relevant research on bioregulators conducted by universities and research centers affiliated with Iran\u2019s military. Bioregulators are molecules produced naturally by the body such as neurotransmitters, hormones, and enzymes that regulate everything from mood to pain signals to vital functions. Biodefense researchers have highlighted the\u00a0potential for misuse<\/a>\u00a0of these compounds as\u00a0incapacitating or lethal bioweapons<\/a>\u00a0agents.<\/p>\n Locations.<\/strong>\u00a0Should any stockpiles of chemical or biological agents or munitions exist, it is unclear where they might be stored. According to tables last published in the\u00a0OPCW\u2019s annual implementation report of 2015<\/a>, Iran had fewer than 10 declared facilities handling chemicals covered by the chemical weapons treaty\u2019s\u00a0schedules 2 or 3,\u00a0<\/a>lists of toxic chemicals that pose varying degrees of risk to the purpose of the convention. Iran had around 100 other declarable and inspectable chemical facilities producing \u201cdiscrete organic chemicals for purposes not prohibited by the Convention.\u201d The Biological Weapons Convention has no inspection or verification regime, making it even more tricky to determine which of the universities and companies that make up\u00a0Iran\u2019s \u201csophisticated\u201d<\/a>\u00a0biotechnology and pharmaceutical industry are of concern.<\/p>\n The Foundation for the Defense of Democracies (FDD), a Washington think tank, in March curated a\u00a0\u201cnon-exhaustive\u201d list of some 10 Iranian entities<\/a>\u00a0sanctioned by the United States and other countries for chemical weapons-related proliferation activities, some of which opposition groups allege have also engaged in bioweapons-related activities.<\/p>\n Notably, some facilities linked to these entities have been bombed or destroyed since the \u201c12-day war\u201d of 2025. Israel\u2019s ambassador to the OPCW\u00a0released a statement<\/a>\u00a0in July of 2025 saying the\u00a0Shahid Meisami Research Complex<\/a>\u00a0was among this number.\u00a0Analysis<\/a>\u00a0by independent researchers confirmed widespread damage. According to the FDD, Israel reportedly also targeted the research complex\u2019s sponsor, the\u00a0Organization of Defensive Innovation and Research (SPND)<\/a>. Separately, the Institute for the Study of War (ISW), an independent public policy research organization, has\u00a0reported<\/a>\u00a0that in 2025 US and Israeli strikes hit the\u00a0Imam Hossein University<\/a>\u00a0(IHU) in Tehran, suspected of working on Iran\u2019s alleged chemical and biological weapons programs as well as its nuclear weapons program. Since the latest strikes started on February 28, the institute reports that\u00a0the Malek Ashtar University (MUT)<\/a>, another site with\u00a0suspected chemical and biological weapons connections<\/a>, was hit and news reports indicate several\u00a0explosions in Karaj<\/a>, a city in western Iran where several suspected sites are located. These include the Defense Chemical Research Laboratory, a facility affiliated with co-authors of a\u00a02022 paper on Novichoks<\/a>, and\u00a0Sina Industry<\/a>, which the National Council of Resistance of Iran called \u201cone of the most important biological and chemical laboratories of the Iranian regime,\u201d \u00a0according to the Wisconsin Project\u2019s Iran Watch.<\/p>\n What next?<\/strong>\u00a0Eliminating Iran\u2019s vast complex of facilities through military means, many of which appear to have legitimate commercial, scientific, and medical purposes, might be possible through an extensive campaign. Eliminating the Iranian chemical and biological weapons knowledge reservoir, even if possible and desirable, seems likely to require radical regime change. While denying that regime change had been an objective, Trump in his Wednesday speech nonetheless argued it had been achieved\u2014a conclusion belied by the evidence so far. Many Iranian regime leaders have been killed\u2014only to be replaced by regime insiders, including the former supreme leader\u2019s son. Further, regional specialists believe regime change will be exceedingly difficult given\u00a0entrenched elites and power bases<\/a>. Should the government manage to hold on to power, as expected, it could well decide to double down on chemical and biological weapons programs, which are easier to hide than a clandestine nuclear weapons effort. An international weapons inspection and destruction mission, such as the United Nations (UN) Special Commission deployed to Iraq following its invasion of Kuwait, seems unlikely in this case given discord on the Security Council, current US government attitudes toward the UN, and Iran\u2019s resistance to International Atomic Energy Agency (IAEA) inspectors.<\/p>\n Nevertheless, the stresses on the Iranian government are severe and authoritarian regimes have collapsed suddenly and unexpectedly in the past, most recently in neighboring Syria. While Syria\u2019s new government is working with the OPCW and international community to identify, declare, and eliminate remaining chemical weapons stockpiles, such sudden transitions generally raise the specter of \u201cworst-case\u201d proliferation scenarios where loss of control over unconventional weapons and related materials and expertise allows them to fall into the hands of non-state actors such as terrorists and criminals. The extensive scale of Iranian dual-use facilities, materials, and knowledge alone suggests that any new regime, ideally one that comes to power through a deliberate and well managed handover, will need to manage outflows of such items to prevent their acquisition by terrorists, criminal networks, and governments with nefarious interest in these capabilities. Even under the best of circumstances, such an effort requires considerable resources to devote to a steep learning and implementation curve.<\/p>\n To successfully address the proliferation threats posed by a country of 90 million people with large industrial and scientific complexes, global leaders in promoting and assisting in the implementation of the export control and border security requirements of international law, especially\u00a0United Nations Security Council Resolution 1540 (2004)<\/a>, will likely need to embark on something akin to the \u00a0multi-year and multibillion-dollar cooperative threat reduction efforts\u00a0<\/a>sustained after the fall of the Soviet Union. In addition to eliminating dual-use\u00a0biological weapons infrastructure<\/a>\u00a0and thousands of tons of bulk chemical agent, the Cooperative Threat Reduction Program provided civilian employment for\u00a0thousands of former weapons scientists with dual-use knowledge<\/a>.<\/p>\n Such an effort in Iran would include refocusing some facilities, setting up science programs or centers to attract those with relevant skills (and their families) to stay in Iran, establishing appropriate and effective legal and enforcement structures, and building compliance programs at an enterprise level. The international community, fortunately, does have at least one mechanism well versed in such efforts, the\u00a0Group of 7 Global Partnership Against the Spread of Weapons and Materials of Mass Destruction (G7GP)<\/a>, a group founded in 2002 to coordinate and deliver major weapons of mass destruction threat reduction and security programming. Given existing commitments\u2014to mitigating biological threats in Africa, countering disinformation, ensuring the complete elimination of Syria\u2019s chemical weapons, and much more\u2014a massive influx of resources and expansion of its programs would be required to address Iran\u2019s legacy weapons of mass destruction programs.\u00a0 But most important, a new regime will have many more immediate concerns, including establishing a new form of government, rebuilding the economy, rooting out corruption, and obtaining justice for those harmed under the old regime without enabling new atrocities. And as in those early post-Soviet years, the most important element of success will be building trust\u2014perhaps the most difficult task of all.<\/p>\n