The fentanyl crisis: From naloxone to tariffs

Vanda Felbab-BrownTHE FENTANYL CRISIS:

FROM NALOXONE TO

TARIFFS

Photo: REUTERS/Jorge Duenes

FOREIGN POLICY AT BROOKINGS 1Executive summary

Over the past several decades, the U.S. opioid

epidemic has spanned four phases:

1. Oversupply of prescription opioids in the

1990s.

2. A significant increase in heroin supply and

use in the 2000s.

3. A supply-driven explosion of fentanyl use

after 2012.

4. Most recently, polydrug use, with fentanyl

mixed into/with all kinds of drugs.

Since fentanyl entered the U.S. illegal drug

market, more than a million people in the United

States have died of opioid overdose.

The costs of fentanyl use go beyond the tragic

deaths and drug-use-related morbidity, however.

In addition to having significant implications for

public health and the economy, the fentanyl crisis

intersects in many ways with U.S. foreign policy.

U.S. overdose deaths began declining in 2023.

But there is little certainty as to which domestic-

or foreign-policy interventions have been crucial

drivers. The wider availability of overdose-re -

versal medication is fundamental, as is expanded

access to evidence-based treatment. It is also

possible that the Biden administration’s actions

toward international supply from Mexico and

China are contributing to this reduction in over -

dose deaths: since the start of 2024, China has

become more active in suppressing the flow

of precursor chemicals, and Mexican cartels,

perhaps purposefully, are now trafficking a less

lethal version of fentanyl. A wide array of policy

measures as well as structural factors outside of

policy control could be cumulatively and interac -

tively reducing mortality.

The fact that the declines in mortality are not

uniform across U.S. ethnic, racial, and social

groups or geographic areas suggests the impor -tance of access to medication for overdose

reversal and the treatment of opioid use disorder,

as well as the influence of structural factors.

There is strong bipartisan support for preserving

access to medication-based treatments. But

crucially, access depends on medical insur -

ance coverage, such as that provided through

Medicaid and the Affordable Care Act. There are

strong ideological divides about the financing

and structure of the U.S. insurance industry as

well as other aspects of drug policy.

On February 1, President Donald Trump imposed

a 25% tariff on imports from Mexico and Canada

and a 10% tariff on imports from China until each

country stops the flow of fentanyl (as well as

migrants, in the cases of Mexico and Canada).1

He gave all three countries a month-long reprieve

before implementing the tariffs in March to see

if they satisfied his counternarcotics demands.

Canada adopted a robust package of anti-fen -

tanyl measures. Mexico too tried to appease the

United States through a set of law enforcement

actions, though it held out on perhaps the most

important form of cooperation—expanding the

presence and mandates of U.S. law enforcement

agents in Mexico to levels at least approaching

those enjoyed during the Felipe Calderón admin -

istration.

Unlike Mexico or Canada, China did not take any

further counternarcotics actions and instead

responded with counter-tariffs of its own, even

as Trump threatened to add additional tariffs on

imports from China of up to 60%.2 On March 4,

2025, Trump dismissed Canada’s and Mexico’s

law enforcement actions as inadequate, imple -

menting the 25% tariffs. He also added an addi -

tional 10% tariff on China, meaning the second

Trump administration has now placed a 20% tariff

on Chinese goods.3

Apart from increasing the cost of goods for

U.S. customers and driving up inflation, these

tariffs will have complex effects on anti-fentanyl

cooperation. Any large U.S. tariffs on China will

likely eviscerate Beijing’s cooperation with the

United States, resetting the diplomatic clock

2  THE FENTANYL  CRISIS: FROM NALOXONE  TO TARIFFSback to the bargaining of 2018 and noncooper -

ation of 2021-2023. As crucial as it is to induce

the government of Mexico to start robustly and

systematically acting against Mexican criminal

groups, whose power has grown enormously and

threatens the Mexican state, Mexican society,

and U.S. interests, Mexico has no capacity to

halt the flow of fentanyl. Mixing the issues of

migration and fentanyl risks Mexico appeasing

the United States principally on migration while

placating it with inadequate anti-fentanyl actions.

Further, U.S. military action in Mexico, which has

been threatened by Republican politicians close

to Trump, would yield no sustained weakening

of Mexican criminal groups or fentanyl flows. It

would, however, poison the political atmosphere

in Mexico and hinder its meaningful cooperation

with the United States.

Strong law enforcement cooperation with

Canada is crucial. Canada has been facing law

enforcement challenges, such as the expansion

of Mexican and Asian organized crime groups

and money laundering operations in Canada. But

disregarding the domestic and collaborative law

enforcement efforts Canada has put on the table

is capricious.

At home, Trump’s favored approach, which

renews focus on imprisoning users and drug

dealers, and dramatically toughening penalties

for the latter, would be ineffective and coun -

terproductive. And while providing treatment is

very important, the dramatic effect of treatment

modality on effectiveness cannot be overlooked.

Approaches to treatment should be designed

based on evidence, not ideology.

Introduction

The fentanyl crisis in the United States will

remain a critical issue for the Trump adminis -

tration. Since 2012, some 530,000 people in

the United States have died of opioid overdose,

with the vast majority of these deaths caused by

fentanyl.4 Also affecting Canada and spreading in

Mexico, the fentanyl epidemic in North America is already the most lethal drug epidemic in human

history. Overdose deaths finally began to decline

in 2023, but they are still at excruciatingly high

levels, inflicting great personal suffering on

families and intense societal costs in terms of

public health and workforce productivity. While

there are many hypotheses as to what has driven

the recent declines in overdose deaths, there are

no definite answers. Yet many policies adopted

during the Biden administration, including the

expanded availability of overdose-reversal

medications and medication-based treatment for

opioid use disorder, have been widely regarded

as positive. The success of such policies,

however, is dependent on broader public health

factors—such as, critically, the availability of

insurance coverage.

The Trump campaign stated its intent to dramat -

ically curb the fentanyl crisis. It centered its

plans on the international supply of fentanyl into

the United States, making fentanyl a central—

and contentious—feature of its foreign policy.

Inaccurately blaming undocumented migrants

for smuggling fentanyl into the United States,

President Donald Trump imposed a 25% tariff

on imports from Canada and Mexico until these

countries stop the flow of fentanyl into the United

States.5 As of March 4, he also imposed fentan -

yl-linked tariffs amounting to 20% on imports

from China and is threatening other tariffs on

imports from China unrelated to fentanyl.6

Such an approach will likely gut the U.S.-China

counternarcotics cooperation that the Biden

administration built up after a two-year hiatus

between 2021 and 2023 and will pointlessly reset

the diplomatic clock to a stage of bargaining

that mixes security, economic issues, and public

health issues. Although the United States gets

virtually no fentanyl from Canada, Mexican

cartels, which produce fentanyl in Mexico and

recruit U.S. citizens to smuggle the fentanyl

into the United States, are critical actors. Their

power grew enormously during the administra -

tion of President Andrés Manuel López Obrador.

The new Mexican administration, headed by

President Claudia Sheinbaum, has indicated far

FOREIGN POLICY AT BROOKINGS 3greater willingness to cooperate with U.S. law

enforcement efforts. If Trump imposes a 25%

tariff for an extended period, it would devastate

the Mexican economy and eviscerate the United

States-Mexico-Canada Agreement (USMCA),

which Trump seeks to renegotiate or even

withdraw the United States from.7 U.S.-Mexico

negotiations to eliminate the tariffs could result

in meaningful counternarcotics and law enforce -

ment cooperation as long as the United States

makes sensible demands: Insisting on unrealistic

goals such as zero fentanyl flow or succumbing

to placating measures by Mexico would be coun -

terproductive and pointless. But how the tariff

pain will intersect with Trump’s migration policies

(e.g., mass deportations) and threats of military

action in Mexico remains to be seen. Military

actions in Mexico would poison bilateral cooper -

ation to such an extent that all law enforcement

cooperation could cease. And mixing fentanyl

and migration risks the Trump administration

achieving desired outcomes on the latter while

giving up on the former as Mexican tariffs also

generate economic pain in the United States.

In addition to its role in U.S. external security and

economic relations with Mexico, Canada, and

China, fentanyl will loom large in U.S. domestic

policies during the Trump administration. The

incoming administration has been far less

specific about its intended policies at home,

but the first Trump administration’s record and

statements made by the most recent Trump

campaign paint a picture of what to expect. It

is likely that significant changes will be made

to the Biden administration’s approach; some

of these changes augur poorly for sustained

and expanded reductions in U.S. fentanyl death

rates and stability for people with substance

use disorders. Proposed changes include resur -

recting a

...

Vanda Felbab-BrownTHE FENTANYL CRISIS:

FROM NALOXONE TO

TARIFFS

Photo: REUTERS/Jorge Duenes

FOREIGN POLICY AT BROOKINGS 1Executive summary

Over the past several decades, the U.S. opioid

epidemic has spanned four phases:

1. Oversupply of prescription opioids in the

1990s.

2. A significant increase in heroin supply and

use in the 2000s.

3. A supply-driven explosion of fentanyl use

after 2012.

4. Most recently, polydrug use, with fentanyl

mixed into/with all kinds of drugs.

Since fentanyl entered the U.S. illegal drug

market, more than a million people in the United

States have died of opioid overdose.

The costs of fentanyl use go beyond the tragic

deaths and drug-use-related morbidity, however.

In addition to having significant implications for

public health and the economy, the fentanyl crisis

intersects in many ways with U.S. foreign policy.

U.S. overdose deaths began declining in 2023.

But there is little certainty as to which domestic-

or foreign-policy interventions have been crucial

drivers. The wider availability of overdose-re -

versal medication is fundamental, as is expanded

access to evidence-based treatment. It is also

possible that the Biden administration’s actions

toward international supply from Mexico and

China are contributing to this reduction in over -

dose deaths: since the start of 2024, China has

become more active in suppressing the flow

of precursor chemicals, and Mexican cartels,

perhaps purposefully, are now trafficking a less

lethal version of fentanyl. A wide array of policy

measures as well as structural factors outside of

policy control could be cumulatively and interac -

tively reducing mortality.

The fact that the declines in mortality are not

uniform across U.S. ethnic, racial, and social

groups or geographic areas suggests the impor -tance of access to medication for overdose

reversal and the treatment of opioid use disorder,

as well as the influence of structural factors.

There is strong bipartisan support for preserving

access to medication-based treatments. But

crucially, access depends on medical insur -

ance coverage, such as that provided through

Medicaid and the Affordable Care Act. There are

strong ideological divides about the financing

and structure of the U.S. insurance industry as

well as other aspects of drug policy.

On February 1, President Donald Trump imposed

a 25% tariff on imports from Mexico and Canada

and a 10% tariff on imports from China until each

country stops the flow of fentanyl (as well as

migrants, in the cases of Mexico and Canada).1

He gave all three countries a month-long reprieve

before implementing the tariffs in March to see

if they satisfied his counternarcotics demands.

Canada adopted a robust package of anti-fen -

tanyl measures. Mexico too tried to appease the

United States through a set of law enforcement

actions, though it held out on perhaps the most

important form of cooperation—expanding the

presence and mandates of U.S. law enforcement

agents in Mexico to levels at least approaching

those enjoyed during the Felipe Calderón admin -

istration.

Unlike Mexico or Canada, China did not take any

further counternarcotics actions and instead

responded with counter-tariffs of its own, even

as Trump threatened to add additional tariffs on

imports from China of up to 60%.2 On March 4,

2025, Trump dismissed Canada’s and Mexico’s

law enforcement actions as inadequate, imple -

menting the 25% tariffs. He also added an addi -

tional 10% tariff on China, meaning the second

Trump administration has now placed a 20% tariff

on Chinese goods.3

Apart from increasing the cost of goods for

U.S. customers and driving up inflation, these

tariffs will have complex effects on anti-fentanyl

cooperation. Any large U.S. tariffs on China will

likely eviscerate Beijing’s cooperation with the

United States, resetting the diplomatic clock

2  THE FENTANYL  CRISIS: FROM NALOXONE  TO TARIFFSback to the bargaining of 2018 and noncooper -

ation of 2021-2023. As crucial as it is to induce

the government of Mexico to start robustly and

systematically acting against Mexican criminal

groups, whose power has grown enormously and

threatens the Mexican state, Mexican society,

and U.S. interests, Mexico has no capacity to

halt the flow of fentanyl. Mixing the issues of

migration and fentanyl risks Mexico appeasing

the United States principally on migration while

placating it with inadequate anti-fentanyl actions.

Further, U.S. military action in Mexico, which has

been threatened by Republican politicians close

to Trump, would yield no sustained weakening

of Mexican criminal groups or fentanyl flows. It

would, however, poison the political atmosphere

in Mexico and hinder its meaningful cooperation

with the United States.

Strong law enforcement cooperation with

Canada is crucial. Canada has been facing law

enforcement challenges, such as the expansion

of Mexican and Asian organized crime groups

and money laundering operations in Canada. But

disregarding the domestic and collaborative law

enforcement efforts Canada has put on the table

is capricious.

At home, Trump’s favored approach, which

renews focus on imprisoning users and drug

dealers, and dramatically toughening penalties

for the latter, would be ineffective and coun -

terproductive. And while providing treatment is

very important, the dramatic effect of treatment

modality on effectiveness cannot be overlooked.

Approaches to treatment should be designed

based on evidence, not ideology.

Introduction

The fentanyl crisis in the United States will

remain a critical issue for the Trump adminis -

tration. Since 2012, some 530,000 people in

the United States have died of opioid overdose,

with the vast majority of these deaths caused by

fentanyl.4 Also affecting Canada and spreading in

Mexico, the fentanyl epidemic in North America is already the most lethal drug epidemic in human

history. Overdose deaths finally began to decline

in 2023, but they are still at excruciatingly high

levels, inflicting great personal suffering on

families and intense societal costs in terms of

public health and workforce productivity. While

there are many hypotheses as to what has driven

the recent declines in overdose deaths, there are

no definite answers. Yet many policies adopted

during the Biden administration, including the

expanded availability of overdose-reversal

medications and medication-based treatment for

opioid use disorder, have been widely regarded

as positive. The success of such policies,

however, is dependent on broader public health

factors—such as, critically, the availability of

insurance coverage.

The Trump campaign stated its intent to dramat -

ically curb the fentanyl crisis. It centered its

plans on the international supply of fentanyl into

the United States, making fentanyl a central—

and contentious—feature of its foreign policy.

Inaccurately blaming undocumented migrants

for smuggling fentanyl into the United States,

President Donald Trump imposed a 25% tariff

on imports from Canada and Mexico until these

countries stop the flow of fentanyl into the United

States.5 As of March 4, he also imposed fentan -

yl-linked tariffs amounting to 20% on imports

from China and is threatening other tariffs on

imports from China unrelated to fentanyl.6

Such an approach will likely gut the U.S.-China

counternarcotics cooperation that the Biden

administration built up after a two-year hiatus

between 2021 and 2023 and will pointlessly reset

the diplomatic clock to a stage of bargaining

that mixes security, economic issues, and public

health issues. Although the United States gets

virtually no fentanyl from Canada, Mexican

cartels, which produce fentanyl in Mexico and

recruit U.S. citizens to smuggle the fentanyl

into the United States, are critical actors. Their

power grew enormously during the administra -

tion of President Andrés Manuel López Obrador.

The new Mexican administration, headed by

President Claudia Sheinbaum, has indicated far

FOREIGN POLICY AT BROOKINGS 3greater willingness to cooperate with U.S. law

enforcement efforts. If Trump imposes a 25%

tariff for an extended period, it would devastate

the Mexican economy and eviscerate the United

States-Mexico-Canada Agreement (USMCA),

which Trump seeks to renegotiate or even

withdraw the United States from.7 U.S.-Mexico

negotiations to eliminate the tariffs could result

in meaningful counternarcotics and law enforce -

ment cooperation as long as the United States

makes sensible demands: Insisting on unrealistic

goals such as zero fentanyl flow or succumbing

to placating measures by Mexico would be coun -

terproductive and pointless. But how the tariff

pain will intersect with Trump’s migration policies

(e.g., mass deportations) and threats of military

action in Mexico remains to be seen. Military

actions in Mexico would poison bilateral cooper -

ation to such an extent that all law enforcement

cooperation could cease. And mixing fentanyl

and migration risks the Trump administration

achieving desired outcomes on the latter while

giving up on the former as Mexican tariffs also

generate economic pain in the United States.

In addition to its role in U.S. external security and

economic relations with Mexico, Canada, and

China, fentanyl will loom large in U.S. domestic

policies during the Trump administration. The

incoming administration has been far less

specific about its intended policies at home,

but the first Trump administration’s record and

statements made by the most recent Trump

campaign paint a picture of what to expect. It

is likely that significant changes will be made

to the Biden administration’s approach; some

of these changes augur poorly for sustained

and expanded reductions in U.S. fentanyl death

rates and stability for people with substance

use disorders. Proposed changes include resur -

recting a law-enforcement-centered, punitive

approach toward users and dealers and perhaps

weakening and defunding some harm-reduction

initiatives. Yet, strong bipartisan support exists at

least for preserving expanded access to over -

dose-reversal medication, such as naloxone, and

treatment medications for opioid use disorder,

such as buprenorphine and methadone.This paper is part of a larger Brookings series,

“The fentanyl epidemic in North America and

the global reach of synthetic opioids,8 that

examines U.S. domestic policy approaches to

fentanyl and opioids, policies regarding the

international supply of illicit fentanyl to the

United States—from countries such as China,

India, and Mexico—and the spread of synthetic

opioids to other parts of the world. It intends

to analyze what is known about the incoming

Trump administration’s plans to address the

opioid crisis. It brings in lessons and findings

from the series’ papers that unpack the state of

the U.S. drug market and the outcomes of U.S.

domestic law-enforcement measures; treatment

and harm-reduction measures; decriminalization

policies, including the impacts of these policies

on specific communities; and policies addressing

international supply. The paper also lays out

various hypotheses about what has driven recent

declines in U.S. overdose deaths. Developing an

accurate understanding of these factors will be

important for sustaining and enlarging reductions

in opioid-related mortality.

This paper proceeds as follows: It first lays out

the evolution of the opioid and fentanyl crisis in

the United States and its four distinct phases,

which reflect changes in the U.S. drug market

and international supply. It then discusses the

reduction in drug overdose mortality in the

United States and lays out hypotheses about

its drivers. It then evaluates elements of U.S.

policy pertaining to opioids, particularly during

the Biden administration but also during the first

Trump administration. Finally, it juxtaposes the

proposals made by Trump and his campaign for

addressing the fentanyl epidemic with the find -

ings of the Brookings fentanyl series.

4  THE FENTANYL  CRISIS: FROM NALOXONE  TO TARIFFSThe evolution of

the opioid misuse

catastrophe and its

costs

The U.S. opioid crisis originated in the 1990s

when unscrupulous pharmaceutical companies

such as Purdue Pharma began promoting new

opiate pain medications, such as OxyContin,

and falsely claiming they were not addictive.9 By

the mid-2000s, these companies had coopted

much of the U.S. public health system to unleash

a heavily commercialized flood of prescription

opioids, whose dosage and application far

exceeded what evidence shows was safe.10

Unprecedented numbers of Americans of all

ages, socio-economic standings, and ethnicities

developed substance use disorders—from high-

school athletes suffering from sprained ankles

and pulled muscles to grandmothers dealing with

age-related chronic ailments. Because doctors

and pharmacies, whether inadvertently or indif -

ferently, were far more effective promoters

of opioid use than any criminal organization,

the resulting rise in substance use disorders

exceeded even the greatest swells in the illicit

drug trade.

Treating pain, especially debilitating pain such

as that produced by terminal cancer, is essential

and needs to be a core focus of health policy.

But the deeply problematic and excessive way

in which pain medications were dispensed in the

United States in the 1990s and 2000s set off

a substance-use-disorder disaster the likes of

which had never been seen.

By the late 2000s, U.S. public health profes -

sionals and policymakers had woken up to the

disastrous trends related to opioid use and

had begun to restrict the supply of prescription

opioids. But the vast numbers of people already

suffering from opioid use disorder could not

break their addictions overnight; instead, they started sourcing prescription opioids from the

illegal market in heroin and OxyContin that had

been developing during the years of overpre -

scription. Heroin use expanded significantly,

and the cultivation of opium poppy in Mexico

exploded. Mexican cartels came to supply heroin

to the United States on a large scale.11

Then came another watershed moment. Despite

heroin from Mexico gushing into the United

States, Chinese traders of chemical products

saw a market opportunity. In 2012, they began

supplying fentanyl, a synthetic opioid, to the

United States, shipping it via postal services

directly to drug retailers. Fifty times more

powerful than heroin and 100 times more than

morphine,12 fentanyl began spreading through the

U.S. drug market as dealers mixed it into heroin.

Even though U.S. users were not seeking fentanyl

out, and even though fentanyl use brought with

it a much higher death rate, the drug’s price-per-

potency ratio, ease of production, and resulting

cheapness proved irresistible to retailers.

Fentanyl originating in China quickly threatened

to steal the illicit opioid market from underneath

the Mexican cartels. Having long dominated the

supply of cocaine, methamphetamine, and heroin

to the United States and having grown to some

of the world’s most powerful criminal groups, the

Mexican cartels—particularly the Sinaloa Cartel

and the Cártel de Jalisco Nueva Generación—

faced a choice: would they try to get into

fentanyl distribution themselves, would they stay

out of it, or would they perhaps seek to eliminate

the retailers distributing fentanyl?

Unlike in Mexico, where criminal groups have

been operating with ever-increasing power,

brazenness, and indifference to an overwhelmed

and deeply infiltrated Mexican law enforcement

apparatus, the cartels were forced to exercise

restraint in the United States.13 Fearing U.S.

law enforcement, they limited the violence and

brutality with which they acted south of the

U.S.-Mexico border, and they did not attempt to

kill the U.S. retailers spreading fentanyl. Instead,

they jumped on the fentanyl bandwagon. By the

FOREIGN POLICY AT BROOKINGS 5mid-2010s, they were buying fentanyl as well as

its precursor chemicals from Chinese producers

and trafficking it into the United States from

Mexico. In May 2019, years of U.S. diplomacy,

spanning both Obama administrations and

Trump’s first White House tenure, succeeded in

persuading China to schedule the entire class

of fentanyl-type drugs, with China hoping that

its counternarcotics cooperation would bring

an end to the tariffs the first Trump adminis -

tration imposed on China. Yet the scheduling

of all fentanyl analogs did not disrupt supply to

the U.S. market. Mexican cartels simply ramped

up their production of fentanyl in Mexico from

precursor and pre-precursor chemicals, most of

which were purchased from Chinese sellers and

through illicit networks.14

By mixing fentanyl into all kinds of drugs,

including cocaine and methamphetamine, both

retailers and the Mexican cartels contributed to

the meteoric rise in drug-related deaths in the

United States, with numbers reaching into the

tens of thousands. The lives lost in the United

States were met with a stunning degree of

indifference by the Mexican cartels, who calcu -

lated that they would get many more Americans

addicted than they would kill through overdose,

as the U.S. Department of Justice indictments

of the Chapitos, the leaders of a key branch

of the Sinaloa Cartel, revealed in April 2023.15

The numbers show little evidence of opioid use

increasing after 2016; the higher toll was driven

almost exclusively by the growing lethality of the

drug supply.16

Mexican criminal groups also perfected the

production of methamphetamine from precursor

chemicals that are unscheduled—and, hence,

difficult to monitor and regulate—producing the

world’s purest, most potent, and increasingly

lethal version of the drug.17

Other developments over the past few years

include mixing new synthetic drugs into fentanyl

and into the drug supply overall. One drug that

currently stands out in this context is xylazine, a

tranquilizer used in veterinary medicine for large animals. The drug first began circulating in the

illicit drug market in Puerto Rico and eventually

took off in Philadelphia and spread across the

East Coast.18 By September 2023, xylazine was

being trafficked to the United States in a solid

form from China, from several other countries in

a liquid form diverted from veterinary supplies,

and from Mexico as part of a fentanyl mix.19

Will the drug, which has been associated with

high-morbidity effects, such as tissue necrosis

and resulting limb amputations, mimic fentan -

yl’s gradual but steady spread across the East

Coast, west to the Mississippi, and eventually

throughout the entire United States? Certainly,

the risks of xylazine are high enough that in

April 2023, the White House designated fentanyl

adulterated with xylazine as an official “emerging

threat” to the country.20

In sum, the U.S. opioid epidemic has gone

through four phases since the 1990s: It started

with an oversupply of prescription opioids,

evolved into a surge in heroin supply and use,

and in the 2010s morphed again into a supply-

driven explosion of fentanyl. This synthetic

opioid, as well as its analogs and other synthetic

opioids such as nitazenes that eventually entered

the U.S. market, was initially shipped directly

from China to the United States in its finished

form; since 2019, these synthetic opioids have

been produced in Mexico using Chinese precur -

sors. The fourth phase of the crisis, in which

the United States currently finds itself, features

polydrug use: fentanyl mixed into/with all kinds

of drugs. It is being adulterated by new synthetic

drugs, such as the high-morbidity tranquilizer

xylazine. It is also being mixed into methamphet -

amine. Yet meth has become increasingly lethal

even on its own.

The costs of the opioid crisis go beyond fatality

counts and mortality rates. The trauma of losing

loved ones to drug overdose spreads through

families and communities, bringing with it inter -

generational mental health consequences as well

as economic burdens and harms. A 2024 study

by Alison Athey, Beau Kilmer, and Julie Cerel

found that more than 40% of American adults

6  THE FENTANYL  CRISIS: FROM NALOXONE  TO TARIFFS(approximately 125 million people) personally

know someone who has died from an overdose,

and 13% of Americans (40 million people) say

those deaths disrupted their lives.21 The conse -

quences of drug-related mortality, in other

words, extend far beyond those who experience

it directly—a community’s functionality and

cultural heritage can be disrupted.

And then there are the multifaceted economic

burdens. In 2019, the U.S. government estimated

the cost of the opioid crisis at $2.5 trillion in

just over four years.22 At that time, U.S. annual

drug death rates were between one-half and

two-thirds of the current death rates. In 2020,

with death rates rising, but nowhere near the

2023 high, the Joint Economic Committee of the

U.S. Senate put the price tag of the U.S. opioid

epidemic at $1.5 trillion.23 Although the U.S.

government has not released updated economic

estimates since that report, it is not unreasonable

to assume that the economic burden has at least

doubled in the intervening period.

Although all social groups in the United States

have been affected by the opioid crisis, and its

fentanyl phase, marginalized communities, rural

communities, the urban poor, and people of color

have disproportionately suffered.24 The severe

fentanyl and opioid costs these communities

bear stem from many causes, but a particularly

important one is a lack of access to evidence-

based treatment modalities, including medi -

cations for opioid use disorder and insurance

coverage for effective treatments. No other

demographic has been hit as hard as American

Indian and Alaska Native communities have.25

The impact on these groups has been not just

intense but also disproportionate in terms of

death rates and community-wide harm. Older

Black men constitute another group among

which the consequences of the opioid crisis have

been disproportionately severe, with the primary

drivers being cocaine use and fatal overdoses.The 2023 and 2024

declines in drug

deaths

After years of crushing trends and dispiriting

numbers, 2023 showed the first decline in

overdose deaths since 2018. In May 2023, the

Centers for Disease Control and Prevention

(CDC) reported the total estimated number of

drug overdose deaths as 107,543 over the past

12 months, a 3% decrease from the 111,029

deaths estimated in 2022.26 Opioid deaths,

including fentanyl deaths, declined from an esti -

mated 84,181 in 2022 to 81,083 in 2023.27 At the

same time, overdose deaths from cocaine, into

which fentanyl is increasingly mixed, and psycho -

stimulants like methamphetamine increased.28

The provisional data reported by the CDC for the

12-month period ending in May 2024 are even

more remarkable, showing a decline of 12.71% in

comparison to the period ending in May 2023.29

That trend continued through June 2024. In

some U.S. states, including some of the worst

affected by fentanyl overdoses, such as Ohio and

Missouri, the reductions in overdoses have been

even more dramatic, reaching 20% and even

30%.30 Together, these figures could amount

to between 16,000 and 31,000 lives saved in

the United States between May 2023 and May

2024.31

As of yet, there are no definitive explanations

for these dramatic reductions. Multiple hypoth -

eses, authoritatively analyzed by Nabarun

Dasgupta, Colin Miller, and Adams Sibley,

could explain the results.32 One possibility is

that the U.S. drug market is finally stabilizing

after increases during the COVID-19 pandemic

and after fentanyl finished spreading across

the entire country. This explanation would be

predominantly a structural one, independent of

policy interventions. The largest fatality drops

have been in U.S. Eastern and Midwestern states,

where fentanyl arrived several years earlier than

FOREIGN POLICY AT BROOKINGS 7in Western states. Combined with the fact that

mortality continued to trend upward in certain

areas of the West in 2024, this suggests that

market saturation, maturation, and stabilization

are, in fact, part of the explanation.

Another possibility is that users have become

more aware of fentanyl’s dangers and that the

entire U.S. drug supply is contaminated with

synthetic opioids. In addition to users spreading

information among themselves, it is possible

that the Biden administration’s intense focus on

prevention and public education, such as through

its One Pill Can Kill campaign, helped to dissem -

inate information about fentanyl-related risks.33

At least some users may indeed be making less

dangerous choices, such as seeking to test drugs

for the absence of fentanyl.34 Yet a reduction

in risky behavior would certainly not present as

a uniform trend across all user groups. Other

users are still seeking out potent fentanyl. And

pill parties, also known as “Skittles” parties or

pharm parties, where teenagers and young adults

contribute drugs from their parents’ medicine

cabinets and the illegal market to a shared bowl

and then randomly draw a handful of drugs to

take to get intoxicated, persist, despite the high

risks of lethal overdose.35

Another possibility, and one with a high likeli -

hood, is that the overdose-reducing medication

naloxone—essentially taboo and barely available

in the United States as recently as two decades

ago—has become far more widespread. First

responders are increasingly equipped with

naloxone, and in all 50 states, naloxone is now

available over the counter without a prescrip -

tion.36 This dramatic change in policy may explain

a large portion of the recent reductions in over -

dose deaths so far. The increased availability of

medications to treat opioid use disorder, doctors’

readiness to prescribe them, and an expansion

of health insurance coverage for substance use

disorders have likely also played a significant role

in the observed reductions.The spread of xylazine may be another, if compli -

cated, factor helping to explain the drop in lethal

overdoses. Xylazine appears to reduce or delay

withdrawal symptoms in some fentanyl users

by having a powerful (yet dangerous) sedative

effect. Thus, instead of a fentanyl user dosing

themselves with fentanyl, say, five times a day

to deal with withdrawal symptoms, which is

not uncommon, they may do so only twice a

day when using a combination of xylazine and

fentanyl.37 Tranquilizer adulterant in fentanyl

might, in other words, delay the fatal effects of

fentanyl in certain cases. However, xylazine, also

known as “tranq,” carries its own risk of serious

side effects, such as severe flesh wounds.

Moreover, xylazine’s powerful sedative effects

put users at risk of becoming crime victims or

being otherwise endangered while using the

drug.

Beyond its serious health effects, xylazine is not

particularly responsive to overdose medication

such as naloxone since it is not an opioid (but,

rather, an alpha-2 agonist). In fact, it has been

found that xylazine may weaken the effect of

naloxone on users who overdosed on a combi -

nation of fentanyl and xylazine.38 Given that

for every lethal overdose, there are roughly 10

nonlethal ones,39 with many lives saved because

of naloxone availability, any reduction in the

effectiveness of opioid-overdose-reversal medi -

cations could drive death rates up again.

It is thus crucial that persons who overdose from

a combination of fentanyl and xylazine receive,

in addition to opioid-overdose-reversal medi -

cation such as naloxone, breathing assistance

to counter the non-opioid sedative effects of

xylazine. Ideally, they would also receive imme -

diate follow-up care by providers skilled in the

latest techniques for addressing xylazine-re -

lated wounds as well as drug treatment for the

complex joint addiction of an opioid and an

alpha-2 agonist.

8  THE FENTANYL  CRISIS: FROM NALOXONE  TO TARIFFSAnother possible explanation for the reduction

in opioid-related mortality is a move away from

opioids and toward methamphetamine, as U.S.

drug market research suggests40 However, with

the lethality of methamphetamine in the U.S.

market steadily increasing, as Peter Reuter and

Greg Midgette show,41 a reduction in opioid

deaths driven by increased methamphetamine

use would provide only a temporary drop in the

overall drug death rate. Moreover, treatment and

harm-reduction interventions for methamphet -

amine are far less developed than they are for

opioids. The super-potent meth now circulating

in the U.S. market is produced in Mexico by

Mexican cartels who possess a unique mastery

of production from very basic chemicals. It is also

increasingly exported to the Asia-Pacific region

via Europe and the Middle East.42

There is also the (somewhat) surprising possi -

bility that the drug supply coming to the United

States features less or less-potent fentanyl. In

various U.S. localities, fentanyl was more expen -

sive and less pure in 2024; in addition, a number

of states across the country—including West

Virginia, Ohio, Arizona, and Maryland—have

reported a fentanyl shortage in interviews with

academic researchers.43 In November 2024,

the administrator of the Drug Enforcement

Administration (DEA), Anne Milgram, announced

that the potency of fentanyl entering the United

States has decreased: in 2023, 70% of fentanyl

pills tested contained a lethal dose, but in 2024,

that number dropped to 50%.44

The Biden administration and U.S. governments

since the Obama administration have certainly

invested heavily in trying to stop the supply

of fentanyl to the United States. These efforts

include increased seizures at the U.S.-Mexico

border as well as extensive arrests of retail-net -

work operatives in the United States, as seen in

DEA operations such as Operation Last Mile.45 In

the 24 months ending in August 2024, the United

States seized more fentanyl—some 70,000

pounds—than in the prior five years combined,

according to U.S. government officials.46 The

Biden administration’s fraught engagement with Mexico, which often produced only limited

responses from López Obrador’s government,

also centered on disrupting the supply of fentanyl

from Mexico.47

As of the end of 2024, however, some experts

were skeptical of the claims of lesser-purity

fentanyl entering the U.S. drug market, pointing

out that illicit fentanyl was more commonly used

in powder form and that no robust and consistent

decreases in the potency of powdered fentanyl

had been detected.48

Even more surprising is the fact that U.S.

policy efforts and pressure on China appear

to have produced a disruption in the supply

of precursor chemicals from China to Mexican

cartels. Certainly, this had been a key goal of the

Biden administration, which engaged in intense

diplomacy with Beijing to get China to schedule

various precursor chemicals and to crack down

on precursor suppliers. And after more than

two years of no cooperation from China, it was

announced in November 2023 that bilateral

counternarcotics cooperation would resume.49

During 2024, a range of joint operations targeting

narcotics and money laundering were carried out,

with the extent of cooperation growing signifi -

cantly after two years of essentially no coopera -

tion.

By late 2024, U.S. officials began reporting that

the supply of fentanyl precursors from China had

indeed decreased.50 In private, Chinese officials

made similar claims.51 Significantly, members of

the Sinaloa Cartel have reported that traditional

fentanyl precursors have become more difficult

to obtain from China, and that, as a result, they

have begun mixing various adulterants into

fentanyl and looking for new ingredients.52

Overall, the evidence of progress in China is

mixed: many Chinese precursor suppliers have

managed to evade Chinese regulations, law

enforcement efforts, and U.S. sanctions by

slightly tweaking their names, and journalistic

investigations still indicate that precursor is both

abundant and easy to acquire in the country.53

FOREIGN POLICY AT BROOKINGS 9As Jonathan P. Caulkins recaps in the Brookings

fentanyl series, reducing the supply of illicit

drugs to the United States and markets around

the world has been an elusive proposition for

decades.54 Increased seizures often reflect

increased drug volume—which was certainly the

case with fentanyl between 2018 and 2023—

rather than an increased rate in law enforcement

effectiveness. Around the world, drugs have

become cheaper, more potent, and more lethal,

despite intense and resource-intensive efforts

to reduce supply.55 Controlling the supply of

synthetic drugs, and especially synthetic opioids,

is particularly challenging—not only are they

inexpensive to produce and easy to smuggle,

but they do not have the same territorial require -

ments as plant-based drugs.56 It has often been

the case that any successes in reducing drug

supply evaporate within a few years, as drug

traffickers find new production localities and

means and new routes and methods of traf -

ficking. Thus, to the extent that there is, in fact,

any reduction in fentanyl supply to the United

States, the important question is whether it can

be sustained.

Certainly, even if China were to stop being the

world’s largest source of illicit precursors—an

unlikely proposition—India, already the world’s

second-largest source of precursors for illicit

drugs, stands ready and waiting. And despite

the Biden administration’s pioneering efforts to

bolster India’s counternarcotics capacities and

establish U.S.-India bilateral cooperation,57 India’s

regulatory and counternarcotics systems remain

deeply inadequate. Moreover, just as they did

with methamphetamine precursors, the Mexican

cartels, particularly the Sinaloa Cartel, have

been investing significant resources and efforts,

such as recruiting university-educated chemists,

toward independent precursor production, which

would greatly reduce their reliance on supply

chains from China or India.58

There is also the intriguing possibility that the

decline in the purity of fentanyl entering the U.S.

drug market is a purposeful change driven by the

Mexican cartels. The two principal producers and traffickers of illicit fentanyl to the United States

are the Sinaloa Cartel, especially the branch

headed by the Chapitos, and the Cártel de

Jalisco Nueva Generación. These groups became

the official top target for U.S. law enforcement in

2024,59 with the United States seeking to arrest

and convict top operatives such as the Chapitos,

the sons of the notorious trafficker Joaquín “El

Chapo” Guzmán Loera, who already resides in a

U.S. prison. In June 2023, while I was conducting

fieldwork in the Mexican state of Sinaloa, where

the Sinaloa Cartel is headquartered, the first

narco banners announcing the Chapitos’ prohibi -

tion of fentanyl production in the state, or at least

its central areas, began emerging.60 So did the

first corpses of those who supposedly violated

the ban. When I was back in Sinaloa in November

2023, I heard from local journalists, nongov -

ernmental experts on the local drug and crime

market, and Mexican government officials that

the ban had remained in place, with an accom -

panying decline in income and a rise in street

criminality in the area.61 But in the spring of 2024,

after seeing no decline in the flow of fentanyl

into the United States, the DEA dismissed the

Chapitos’ announcement as a public relations

stunt designed to deflect U.S. and Mexican law

enforcement pressure or perhaps consolidate

market control.62

Nonetheless, it is possible that in order to reduce

law enforcement pressure in their home base

of Culiacán and central Sinaloa, the Chapitos

decided to approach fentanyl overdose deaths

in the United States in a similar manner to deaths

by violence north of the U.S.-Mexico border.

Thus, in addition to moving fentanyl production

to southern and northern Mexico, they began

supplying less-potent, more-adulterated fentanyl

within the United States. In fact, Milgram, the

DEA administrator, explicitly stated in November

2024 that the “cartels have reduced the amount

of fentanyl they put into pills because of the

pressure we are putting on them.”63

Meanwhile, the evidence from the field is mixed.

There have certainly been points at which

cartel operatives instructed fentanyl cooks to

10  THE FENTANYL  CRISIS: FROM NALOXONE  TO TARIFFSmake batches stronger and to look for ways of

increasing the product’s potency.64 At least some

of these instructions were given in 2023 and

even in 2024. In late 2024, the Sinaloa Cartel also

carried out experiments in which, in exchange for

small payments, vulnerable inhabitants of Sinaloa

were injected with fentanyl, despite the risks of

lethal overdose—and many did indeed die in the

process. Similar experiments were performed on

animals. But the cartel’s cooks seem not only to

be looking to weed out excessively potent—and,

thus, excessively lethal—fentanyl baches; they

also appear to be focused on weeding prod -

ucts that are too weak for U.S. consumers. So,

have they become more responsive to U.S. law

enforcement? Perhaps.

The Sinaloa Cartel is highly decentralized—

and not just because of the intense warfare

between the Chapito and the Mayito branches

following the Chapitos’ betrayal of Ismael “El

Mayo” Zambada García.65 Fentanyl production

and distribution are often left to underlings,

with the top bosses only occasionally imposing

system-wide orders. Some mid-level bosses may

be unconcerned about U.S. law enforcement

efforts or any orders from the Chapitos. But U.S.

law enforcement agents interrogating the two

Chapitos and El Mayo—all of whom are now

in U.S. custody—can at least find out where in

the United States the cartel ordered less-lethal

fentanyl to be sent as a result of U.S. arrests and

law enforcement pressure. In their interrogations,

they can and should ask about the cartel’s stra -

tegic decisions and responses, if there have been

any, to U.S. law enforcement efforts. If it can be

confirmed that the Chapitos decided to purpose -

fully reduce the potency of fentanyl in the U.S.

market on account of U.S. law enforcement pres -

sure, that would be a significant accomplishment

for U.S. law enforcement.

Indeed, many questions about what has driven

the reductions in overdose deaths remain. While

various hypotheses have been offered, there are

few definitive answers. Acquiring such answers,

or at least developing well-reasoned analyses of

possible factors and their plausibility as drivers of improved outcomes, is crucial for sustaining and

deepening the declines in drug overdose deaths

and saving U.S. lives. The papers collected in

the Brookings series “The fentanyl epidemic in

North America and the global reach of synthetic

opioids” did not set out to provide these answers.

The decreases in deaths only became strongly

apparent once the papers were written. However,

the papers assess the effectiveness of a wide

range of policy measures, dealing with both

internal and external supply, and bring together

a considerable body of knowledge about federal

policies, state-level experimentation, and their

outcomes. The papers thus provide an invaluable

foundation for continued investigation of causal

factors as well as efforts to sustain reductions

and further improve policies.

One finding, however, is unequivocal, and it’s

not a positive one: the declines in deaths did not

take place uniformly across U.S. ethnic, racial,

and social groups. The declines in drug overdose

deaths mostly occurred among white Americans;

on the whole, in fact, overdose deaths among

Black Americans increased between 2022 and

2023.66 In Maine, lethal overdoses dropped by

20% among white people but increased by a

shocking 40% among Black people. In Michigan,

they went down 12% among white people but

increased 6% among Black people.67 In Arizona,

lethal overdoses declined by over 2% among

white people but increased by a third among

Black people. In states where overdose deaths

declined for both groups, they did so more for

white people. In states where lethal overdoses

increased for groups, they did so more for Black

people. Similarly, localities that tracked over -

doses for American Indians, Alaska Natives,

and Hispanics found far worse trends for those

groups than for white people.68

These disparities are distressing but, sadly, not

surprising. Various papers, especially papers

in this series, such as those by Nicole Gastala,

Harold Pollack, et al.; Regina LaBelle and David

Holtgrave; and Philomena Kebec, point out that

access to overdose medication and effective

treatment is highly unequal69: Rural communities

FOREIGN POLICY AT BROOKINGS 11tend to have less access than urban ones, and

low-income individuals struggle with high trans -

portation costs, inaccessibility of treatment facil -

ities, and unavailability of treatment modalities. In

the case of non-white ethnic and racial groups,

who have historically suffered from injustice

and inequity, these factors have a tendency to

combine in disastrous ways.

Clearly, further policy improvements need to

focus on expanding access to effective treat -

ment and overdose medication for marginalized

groups, in addition to funding and expanding

such approaches overall. But will the push by the

Trump administration to defund and eliminate all

federal diversity, equity, and inclusion (DEI) initia -

tives undermine providing badly-needed support

to those groups?70

U.S. policy responses

Even while further policy adjustments are

badly needed, along with expanded funding for

effective, evidence-based interventions, there

have been significant improvements, dramatic

changes, and ground-breaking innovations since

the beginning of the Obama administration.

Unlike many other aspects of public policy in the

United States, these improvements came about

with significant bipartisan backing. Crucial legis -

lation passed since the Obama administration

includes the following:

■ The Comprehensive Addiction and

Recovery Act of July 2016, which allocated

$181 million annually toward prevention,

recovery, and treatment (including for

incarcerated individuals); law enforcement;

criminal justice reform; and the distribution of

overdose-reversal medication.

■ The 21st Century Cures Act of December

2016, which established a federal funding

account for state responses to the opioid

crisis, created the position of assistant

secretary for mental health and substance

use within the Department of Health and Human Services, and increased access to

information on evidence-based programs and

practices regarding substance use.

■ The SUPPORT Act of October 2018, which

allocated federal funds for prevention,

treatment, education, medical insurance,

and law enforcement and community-based

programs pertaining to the opioid crisis.

■ The Rural Opioid Abuse Prevention Act of

December 2022, which expanded the allow -

able uses of grant funds provided through

the Comprehensive Opioid, Stimulant, and

Substance Abuse Program, administered

by the Department of Justice, to include

pilot programs in rural areas aimed at using

community-centered methods (including

alternatives to incarceration) to reduce opioid

overdose deaths.

■ The FENTANYL Results Act of December

2022 (part of the FY23 National Defense

Authorization Act), which directed the

State Department to combat international

trafficking of synthetic drugs and fentanyl

through enhanced collaboration with inter -

national partners, with special focus on

improved data collection, increased engage -

ment with international drug agencies, the

provision of technical equipment and training

to boost capacity building abroad, and the

creation of exchange programs with foreign

governments and nongovernmental organiza -

tions for education and training.

■ The END FENTANYL Act of March 2024,

which required U.S. Customs and Border

Protection to review and update inspection

practices at ports of entry to ensure unifor -

mity and effective detection of illegal activity

along the border, such as the smuggling of

drugs and humans.

■ The FEND Off Fentanyl Act of April 2024

(included in the supplemental national secu -

rity bill H.R. 815), which expanded sanction

authority on illicit fentanyl traffickers in

Mexico and producers of precursor chemi -

cals in China. This act allows the proceeds

from forfeited sanctioned property to be

put toward law enforcement efforts and

12  THE FENTANYL  CRISIS: FROM NALOXONE  TO TARIFFSempowers the U.S. Treasury Department to

use special measures against money-laun -

dering activities connected to the fentanyl

trade.71

In recent years, the United States has broken

with its decades-long policy of disavowing and

prohibiting harm-reduction measures, with the

Biden administration being the first to embrace

harm reduction in its national drug strategy.72

Drugs like naloxone, taboo in the 1990s and

2000s, are increasingly seen as essential.

Despite various challenges, including legal ones,

overdose centers have begun to emerge.73 The

United States also invested far more in medi -

cation-based treatment for opioid use disorder.

Although methadone had been federally funded

in the United States for decades, numerous

barriers plagued its access. Federal and state

efforts to reduce these barriers increased as

knowledge about the effectiveness and impor -

tance of evidence-based medication spread

among communities and among members of the

medical profession. Since the Obama admin -

istration’s pioneering efforts, health insurance

coverage for drug use disorders and mental

health treatment has also increased.

Despite these important policy developments,

however, there is still a long way to go. Many

barriers to accessing naloxone and other medica -

tions still stand, and insurance coverage remains

woefully insufficient. According to one estimate,

of the roughly 7.9 million people suffering from

opioid use disorder in the United States, only

6% received treatment at a specialty facility in

2022 and only 3.6% received medication for

opioid use disorder.74 Only 24% of people with

any substance use disorder (including alcohol

use disorder) received any type of treatment in

2022.75 While some users of opioids may be able

to quit without treatment, many who need and

want treatment still cannot readily access it.

As discussed in various papers from the

Brookings fentanyl series, including those by

Gastala, Pollack, et al. and Kebec,76 many barriers

to treatment access persist—in addition to the problem of health insurance, these include

stigma, lack of doctor awareness and training,

and the unequal provision of health care due

to geographic, economic, social, and historical

factors. These barriers are particularly high for

people of color and for members of the incarcer -

ated population.

Not all policy experimentation has been effective

or sustained. Decriminalization policies enacted

along the Pacific coast from California to British

Columbia became associated with a range of

negative outcomes, such as street criminality

and open drug markets, and were reversed, as

Keith Humphreys outlines.77 Moves by various

U.S. jurisdictions to classify the distribution of

fentanyl leading to lethal overdose as a murder

offense may be similarly ill-advised, as Beau

Kilmer and Roland Neil lay out in their paper on

various aspects of and changes in U.S. domestic

drug law enforcement.78

Other experimentation, such as with the govern -

ment’s provision of safer opioid medications

(hydromorphone and oral morphine, for example),

stimulant medications, and benzodiazepines, is

ongoing in British Columbia.79 Despite its vaunted

harm-reduction approaches, the province has

struggled to cope with fentanyl overdoses,

as Jonathan P. Caulkins lays out in his paper

evaluating different approaches to dealing with

recreational drug markets.80 And fentanyl and its

associated mortality continue to spread eastward

across Canada, which has tallied over 44,500

opioid overdose deaths since 2016.81

Much of the U.S. response to the opioid crisis

focuses on reducing supply. U.S.-China bilateral

cooperation collapsed at the beginning of the

Biden administration. Although China prides

itself on being the world’s toughest drug cop, it

subordinates and instrumentalizes its counter -

narcotics and law enforcement cooperation to

higher priorities in its foreign policy. For example,

when China did not get the expected payoff of

reduced tariffs from the Trump administration,

and when the Biden administration retained those

tariffs and even increased strategic competi -

FOREIGN POLICY AT BROOKINGS 13tion in many domains, China suspended its law

enforcement cooperation with the United States.

By late 2023, however, adroit U.S. diplomacy

created impactful pressure points on China—

not only in the bilateral relationship but also in

the multilateral sphere, through the creation of

the Global Coalition to Address Synthetic Drug

Threats. Moreover, both China and the United

States, for their own strategic and economic

reasons, sought to stabilize the bilateral rela -

tionship and find possible areas of cooperation.

Counternarcotics cooperation restarted and

yielded results.

Though hampered by its reliance on Mexico for

stopping migrant flows, the United States also

sought to work with the López Obrador adminis -

tration on disrupting the fentanyl supply. Halting

and at various times riddled with deception,

as I discuss in my March 2024 congressional

testimony,82 the López Obrador administration’s

anti-fentanyl policies were largely inadequate.

Crucially, López Obrador’s disavowal of law

enforcement approaches to Mexican criminal

groups, in the futile hope that these groups

would settle their disputes independently and

that Mexico’s violence would decline as a result,

effectively handed the country over to the

narcos. The arrival of the Sheinbaum administra -

tion provides new opportunities for counternar -

cotics and law enforcement collaboration83—if, as

is also the case with China, the Trump adminis -

tration’s tariffs and other policies toward Mexico

and China do not instead disrupt all enforcement

cooperation.Fentanyl and the

second Trump

administration’s

policies

In its first month, the Trump administration

intertwined drug approaches to an unprece -

dented degree with U.S. national security and

economic policies. It thrust fentanyl to the center

of its relations not just with Mexico and China

but also with Canada, even though Canada has

not been a source of fentanyl supply for the

United States. On February 1, 2025, the Trump

administration imposed a 25% tariff on all imports

from Mexico and Canada and a 10% tariff on all

imports from China until each country fully stops

the flow of undocumented migrants and fentanyl

to the United States.84 To avert the economi -

cally-devastating tariffs, Mexico and Canada

offered varying law enforcement packages to

satisfy the Trump administration and obtained a

one-month deferment of the tariffs’ implementa -

tion. But Trump declared Canada’s and Mexico’s

measures to be inadequate. Unlike Mexico and

Canada, China did not come running with new

counternarcotics measures in an attempt to

halt the tariffs. Thus, on March 4, the Trump

administration implemented the 25% tariffs on

Mexico and Canada and imposed additional 10%

fentanyl-linked tariffs on China, for a total tariff

of 20%.85

14  THE FENTANYL  CRISIS: FROM NALOXONE  TO TARIFFSThe Trump administration also launched another

policy that the previous administration consid -

ered too extreme and counterproductive: desig -

nating Mexican drug trafficking groups as foreign

terrorist organizations (FTOs).86

During the 2024 presidential campaign, Trump

repeatedly threatened to place tariffs on Mexico

and the FTO designation on Mexican cartels. The

question now is whether the Trump administra -

tion will also deliver on the Trump campaign’s

threats of unilaterally bombing Mexican cartels

or deploying U.S. special operations forces to hit

them in Mexico.

The Trump campaign was far less specific about

its intended fentanyl policies at home, but it

emphasized tough domestic law enforcement

measures. The campaign’s statements as well as

the Trump administration’s dramatic reductions

to the federal workforce and funding suggest

significant changes are coming to the U.S.

federal strategy toward combatting fentanyl

and illicit dangerous drugs. Some of these poli -

cies augur poorly for sustaining and expanding

the reductions in U.S. fentanyl death rates and

stabilizing the lives of people with substance use

disorders.

Supply-side

measures

The Trump campaign’s fentanyl plans mostly

centered on tough messaging around drug

supply, linking fentanyl deaths to what it called “a

wide open U.S. southern border.”87 His promises

to “secure” the U.S. border focused on reducing

the number of migrants coming into the United

States, an objective he also linked to reducing

U.S. fentanyl overdoses. Trump repeatedly

accused migrants of smuggling fentanyl into

the United States, as well as “poisoning the

blood of our country,”88 a comment JD Vance

attempted to reinterpret as meaning that “the

blood of Americans is being poisoned by a drug

epidemic.”89 Apart from its racist connotations, this statement is highly inaccurate: according to

the U.S. Sentencing Commission, 86.4% of those

convicted on fentanyl trafficking charges in FY

2023 were U.S. citizens.90 Ninety-three percent

of fentanyl seizures occurred at legal crossings

or at interior vehicle checkpoints, rather than on

illegal migration routes.91

Trump also regularly blustered about U.S. mili -

tary actions against Mexican criminal groups

inside Mexico, insisting on “full cooperation”

from neighboring governments in dismantling

trafficking networks.92 During the presidential

campaign, Trump asked his team to draw up “a

battle plan” against the cartels.93 Along with his

advisors and many Republican politicians, Trump

called for various military actions against the

cartels, ranging from missile strikes on Mexican

drug labs and special-forces operations targeting

cartel operatives in Mexico to a U.S. naval

blockade of Mexican ports known to be signifi -

cant hubs for fentanyl precursor.94

DESIGNATING MEXICAN CARTELS AS

FOREIGN TERRORIST ORGANIZATIONS

Many Republican politicians close to Trump,

including Vance, also argued for adding Mexican

cartels to the list of designated FTOs.95 On his

first day in office, Trump delivered on the threat,

tasking the Department of State to designate

Mexican cartels as well as other transnational

criminal groups as FTOs. As of February 12,

the State Department’s working list included

six Mexican criminal groups: the Sinaloa

Cartel, Cártel de Jalisco Nueva Generación,

the Northeast Cartel, La Familia Michoacana,

Carteles Unidos, and the Cartel del Golfo.96 The

Tren de Aragua, originating in Venezuela, and

Mara Salvatrucha, spanning the United States

and Central America, are also expected to be

included on the official list.

The FTO label brings some benefits, but mostly

has counterproductive effects, as I lay out in

my February 2025 Foreign Affairs piece “The

New War on Drugs.”97 Because the designation’s

downsides outweigh its few upsides, the Obama

FOREIGN POLICY AT BROOKINGS 15and Biden administrations, both of which also

considered making this designation, rejected

the idea. In his first administration, Trump badly

wanted to make the designation, but his advisors

talked him out of it.98

The FTO label does not empower the United

States with any stronger financial sanctions

against Mexican cartels than those already

stemming from their criminal activity.”99 Nor

does it provide direct authorities for launching

military strikes into Mexico. The FTO designation

is not needed for that, the U.S. president can

authorize such strikes without a congressional

declaration of war even in the absence of such

a designation—viz., the Biden administration’s

strikes against the Houthis in Yemen after the

U.S. government removed the FTO designation

from the Houthis.100 The label does expand some

of the U.S. Department of Defense’s authorities,

such as in intelligence collection. And indeed,

raising the prioritization of intelligence collection

on the Mexican cartels is very important and a

benefit of the designation. But the Biden adminis -

tration had already increased intelligence collec -

tions on the cartels without the designation. The

label may also increase the prioritization that

Department of Justice prosecutors give to narco-

linked cases, which would be another benefit.

But the FTO designation comes with vast, nebu -

lous, and powerful material support clauses. The

knowing provision of even a glass of water—and

perhaps even of advice—can be prosecuted by

the U.S. Department of Justice and result in large

financial penalties or imprisonment. While the

material support clauses allow exceptions for

duress—i.e., providing payments or other support

under the threat of violence or death—the

duress clauses have not always been sufficient

in courts in the United States and elsewhere in

the world to assure legal relief.101 Thus, anyone

from Chinese brokers selling precursor chemicals

to the Mexican cartels, to migrants paying them

smuggling fees or ransom, to Mexican compa -

nies or individuals forced to pay extortion, could

be prosecuted by the Department of Justice or

sanctioned by the U.S. Department of Treasury and cut off from the U.S. financial system or

denied asylum. Given the pervasiveness of

extortion in Mexico, the designation has—unsur -

prisingly—been opposed by successive Mexican

governments.

U.S. financial service providers might be reluc -

tant to process remittance payments to Mexico,

fearing that some of the money in Mexico could

leak to the designated Mexican criminal groups.

In 2023, remittances from the United States to

Mexico amounted to $63.3 billion, some 4.5% of

Mexico’s GDP.102 A decline in remittances would

be a blow to the Mexican economy, which now

also has to grapple with decreased remittances

as a result of the mass deportations of undoc -

umented migrants by the Trump administration

and the high costs of absorbing the deport -

ees.103 To appease the Trump administration,

the Mexican government also agreed to host

deportees from the United States who are not

Mexican nationals.104

Since there is no territorial limitation to the mate -

rial support clauses, U.S. companies and indi -

viduals too could be held legally liable. The legal

liability would strongly pertain to U.S. gunmakers

and gun sellers, an important constituency of

Trump and the Republican Party.

But many other U.S. economic firms and individ -

uals could be charged with material support to

terrorist groups if their Mexican subsidiaries or

other business partners paid extortion fees to

the Mexican cartels or otherwise engaged with

them.105 The extent of due diligence that U.S.

companies will need to undertake about their

Mexican counterparts will increase substantially.

If the U.S. government mounted extensive prose -

cutions, U.S. companies could become reluctant

to trade with or invest in Mexico and may even

divest from the country.

Such economic fallout would constitute another

serious blow to the Mexican economy. Moreover,

it would undermine the Biden administration’s

efforts to reduce U.S. economic dependence

on China by moving supply chains closer to U.S.

16  THE FENTANYL  CRISIS: FROM NALOXONE  TO TARIFFSsoil and to U.S. allies and neighbors. The inward-

looking Trump administration may not care about

weakening the Mexican economy or undermining

near-shoring as it seeks to relocate much of the

supply chains to the United States itself.

TARIFFS ON MEXICO

Indeed, the 25% tariff on Mexican imports that

Trump says will stay in place until the country

stops the flow of migrants and fentanyl into

the United States is an outright violation of the

USMCA trade agreement the president had

negotiated with Mexico and Canada during his

first administration.106 Eager to avoid the tariff,

which the Peterson Institute of International

Economics estimates would result in the loss of

as much as 2% to 3.5% of real Mexican GDP over

the next decade (assuming Mexico retaliates

in kind),107 the Mexican government under -

took various measures, including deploying an

additional 10,000 National Guard troops to the

U.S.-Mexico border on top of the 15,000 troops

previously deployed there.108 At least on some

parts of the border, the troops began inspecting

every single vehicle heading to the United States,

though they are finding little fentanyl, with the

cartels likely temporarily suspending this method

of fentanyl smuggling.109 But they have been

preventing migrants from reaching the U.S.

border, with migrant arrivals at the border low in

late 2024 and early 2025.

On February 28, the Mexican government also

handed over to the United States 29 top cartel

bosses and other top-level operatives who

were imprisoned in Mexico.110 Among them was

Rafael Caro Quintero, one of the founders of the

Sinaloa Cartel and a top operative of the earlier

Guadalajara Cartel, who had been sought by

U.S. law enforcement for 40 years for his role

in the kidnapping, brutal torture, and murder of

DEA agent Enrique “Kiki” Camarena in 1985. This

handover provides both justice and closure and

allows U.S. law enforcement agents to inter -

view the traffickers about their operations and

corruption networks in the U.S. government. It is

a significant move.Finally, the Mexican government has been

conducting widespread arrests and fentanyl lab

busts in Sinaloa to deflect tariffs and reduce

the violence that has flared up in the state

since September 2024. In November 2024, the

Mexican government announced it had busted

the largest-ever fentanyl lab in Mexico.111

The tariff threats have created important

leverage for the U.S. government. The López

Obrador administration’s anti-crime efforts and

cooperation with the United States had been

woefully inadequate. The Sheinbaum administra -

tion has shown far more willingness to cooperate

with the United States. But the Trump adminis -

tration must ask for the right deliverables from

Mexico, given the infeasibility of Trump’s demand

of zero fentanyl flow from Mexico into the United

States.112 Washington should not be satisfied with

Mexico predominantly countering the flows of

migrants to the U.S.-Mexico border. Nor should it

allow itself to be placated with sporadic counter -

narcotics actions, such as the occasional high-

value targeting of top narcos, the destruction

of labs, or drug seizures, even if large ones, the

principal actions the Mexican government has

undertaken so far.

AMERICA, MEXICO, AND THE

CONSEQUENCES OF TRUMP’S POLICY

On their own, all of these actions are ephemeral

in their impact, and high-value targeting has

amplified violence in Mexico, a bad development

that is making anti-crime measures in Mexico

hard to sustain.113 Instead, Washington should

bargain for the resurrected, extensive presence

of U.S. law enforcement officials, including from

the Drug Enforcement Administration, in Mexico.

In collaboration with Mexican security forces and

with expanded mandates, U.S. law enforcement

agents in Mexico could refocus targeting away

from only the top narcos toward Mexican criminal

groups’ middle operational layers, a move that

interests the Sheinbaum administration and would

stop new leaders from taking over and continuing

the crime organizations’ illegal business.114 It will

take a long time to rebuild mutual trust, especially

FOREIGN POLICY AT BROOKINGS 17to the level we temporarily saw during the Felipe

Calderón administration and the Merida Initiative,

a U.S.-Mexico bilateral security agreement.115

However, such an expanded U.S. presence would

facilitate intelligence gathering, strategic anal -

ysis, and response, thereby rolling back Mexican

criminal groups from the legal economies they

penetrated in Mexico and holding Mexican security

forces and government officials accountable. Yet

the Sheinbaum administration has so far resisted

allowing a greater scope of operations for U.S. law

enforcement agents in Mexico, even if they were to

work jointly with Mexican law enforcement officials.

If the tariffs eventually prompt such expanded

cooperation from the Mexican government,

the United States will need to help design law

enforcement strategies to reduce violence in

Mexico. This could be accomplished through

careful sequencing and prepositioning forces in

concentric circles of operations. Helping Mexico

build investigative capacities, another element

Sheinbaum has embraced,116 is crucial. So is

finding ways to insulate Mexican prosecutors and

judges from corruption and violent threats from

the narcos. This has become far more difficult

since Mexico passed a constitutional reform in

September 2024 mandating the election of all

judges.117 Mexico’s judicial system thus became

not just politicized but even more vulnerable to

the narcos, who now influence Mexican elections

to an unprecedented degree.118

Of course, the United States will waste its

leverage with Mexico if it continues imposing

tariffs even if Mexico complies with U.S. coun -

ternarcotics demands. Beyond the 25% fentan -

yl-linked tariff, the Trump administration’s tariffs

on steel and aluminum hit Mexico (as well as

Canada) particularly hard.119 Trump has also

threatened to impose a 25% tariff on automobiles

as of April 1, another move with vastly detri -

mental impact on Mexico and Canada.

The Mexican government reacted to the imple -

mentation of the 25% fentanyl-linked tariff by

imposing counter-tariffs.120 It has other retaliatory

actions at its disposal: It could halt its efforts against migrant flows, allowing them to reach

the U.S.-Mexico border. It could also scale law

enforcement cooperation back or perhaps even

expel U.S. law enforcement agents.

A more escalatory step, which would completely

blow up U.S.-Mexico law enforcement coopera -

tion, is if the United States resorts to unilateral

military actions in Mexico. Bombing drug labs or

killing cartel leaders would be of limited effec -

tiveness in weakening the power of the Mexican

criminal groups and reducing the supply of drugs

to the United States. Much like the so-called

high-value-targeting approach taken by three

successive Mexican administrations against

drug kingpins, U.S. military attacks against cartel

leaders, even if successful in killing them, would

fuel more violence in Mexico without preventing

these groups from reconstituting. Similarly to the

destruction of labs, which would only modestly

reduce drug flows because they are easy to

rebuild, cartel leadership is easy to replace, even

if doing so results in additional bloodshed.121

Thus, while unilateral U.S. military action in

Mexico would have limited effectiveness, it would

also be politically explosive in the country and all

but guarantee the Mexican government’s refusal

to cooperate with U.S. anti-cartel efforts. This

would be especially likely if U.S. military actions

caused civilian casualties, something that could

easily happen as Mexico’s crime bosses and

clandestine labs often operate in cities. In fact,

the U.S.-Mexico security relationship would likely

deteriorate to its worst point in decades, bringing

a broad range of U.S. interests into jeopardy.

The Trump administration cannot have it both

ways: it cannot conduct unilateral strikes in

Mexico and expect robust Mexican cooperation

in dismantling trafficking networks. Of these, the

latter is far more important for addressing drug

flows and for securing other key U.S. interests.

Nor should it impose extensive tariffs on Mexico

once Mexico agrees to robustly strengthen

anti-crime efforts, including by permitting an

expanded presence and range of operations of

U.S. law enforcement agents.

18  THE FENTANYL  CRISIS: FROM NALOXONE  TO TARIFFSCANADA

The 25% fentanyl- and migration-linked tariffs

the Trump administration announced on February

1 and implemented on March 4 also applied

to Canada. That move, profoundly disrupting

relations with one of the United States’ closest

allies and compounding Trump’s threats to use

economic tools to annex Canada,122 makes little

sense.

Canada is grappling with a devastating fentanyl

crisis of its own. Between January 2016 and

June 2024, Canada registered 49,105 apparent

opioid overdose deaths.123 The country has also

seen a dangerous expansion of organized crime

and money laundering, including for Mexican

cartels. According to Canadian law enforce -

ment officials, there are also signs that Mexican

cartels may be gearing up to start producing

some drugs—whether fentanyl or methamphet -

amine—in Canada.124 Until now, they have been

using Canada mostly as a transshipment route

for their meth and cocaine heading to the Asia-

Pacific region and precursors heading to their

production sites in Mexico. Fentanyl in Canada

has been produced by atomized producers, even

if operating very large labs, and distributed by

Canadian biker groups.125

Yet only a tiny fraction of the fentanyl that comes

into the United States originates in Canada:

in 2024, it was only 0.2%. Overwhelmingly,

fentanyl is supplied to the United States by

Mexican cartels out of Mexico.126 In fact, more

fentanyl has been heading from the United

States to Canada than vice versa. In 2023, the

U.S. Customs and Border Protection agency

seized only 43 pounds of fentanyl coming from

Canada to the United States while it seized

21,148 pounds heading to the United States from

Mexico and 882 pounds heading from the United

States to Canada!127

Nonetheless, the prospect of a dramatic disrup -

tion to U.S.-Canada trade and to Canada’s

economy as well as Trump’s threats of annex -

ation spurred the Canadian government to strengthen a variety of law enforcement

measures: Canada announced an additional

$910 million for increased personnel, technology,

and canine units at the U.S.-Canada border.128

It created the position of a fentanyl czar and

appointed a former senior law enforcement

official and high-level security and intelligence

officer, Kevin Brosseau, to the job. Since taking

up the post, Brosseau has committed himself

to Trump’s impossible demand of zero fentanyl

flows from Canada to the United States.129

Despite the massive legal tangles that imple -

mentation would require, Ottawa also agreed to

designate Mexican cartels as terrorist groups.130

Perhaps most significantly, it proposed the

creation of a Canada-U.S. Joint Strike Force

tasked with combatting organized crime and

money laundering, dedicating $140 million (CAD

200 million) to it. If trust and a collaborative mood

can be created in the task force, it could become

a highly powerful and valuable tool against

organized crime in Canada and the United States.

However, these actions did not satisfy the Trump

administration, which imposed a 25% tariff on

March 4. Canada reacted with a 25% retaliatory

tariff against $107 billion dollars’ worth of U.S.

goods.131

CHINA

Trump’s fentanyl-linked tariffs also apply to

China. At first, Trump threatened a smaller rate

of 10%.132 But when China did not respond with a

slate of new counternarcotics initiatives, Trump

imposed an additional 10% tariff on March 4.

He has also threatened to impose other tariffs

on China, as much as 60%, for non-fentanyl

reasons.133 The tariffs are unlikely to substan -

tially advance Chinese counternarcotics coop -

eration with the United States. Already, China

has retaliated with counter-tariffs, and the law

enforcement cooperation that was built up during

the last year of the Biden administration could

easily be set back, instead of being cemented

and expanded.

FOREIGN POLICY AT BROOKINGS 19The Trump administration’s decision to place

tariffs on China is not surprising. In 2023, Trump

warned that China would “pay a steep price”

for not clamping down on illicit drug precursor

flows.134 Trump also claimed that Chinese

President Xi Jinping had promised to impose

the death penalty on Chinese producers and

traffickers of fentanyl and fentanyl precursors: “I

had a deal worked out with President Xi,” Trump

claimed in 2023. “They weren’t going to be

sending any more [fentanyl to the United States],

and they were going to impose the death penalty

on those that made it in China.”135

Chinese laws do include the death penalty for

drug trafficking, but in practice, China rarely

issues such a sentence. Moreover, many synthet -

ic-opioid and methamphetamine precursors are

unscheduled legal chemicals: the key obstacle to

China’s law enforcement actions is the absence

of racketeering-conspiracy and material-sup -

port clauses in China’s laws. For this and many

other reasons, it is hard to imagine that Xi ever

agreed to or would agree in the future to such

law enforcement and judicial actions. But will the

Trump administration insist on any such measures

in its engagements with China over fentanyl?

JD Vance, too, has threatened intense punitive

actions against China: “We should be willing to

say [to China], that if you don’t stop sending

fentanyl precursors to Mexico and to our own

ports of entry, we’re going to really penalize you

guys economically. … We can increase tariffs and

extract a massive economic cost.”136

Vance has also flirted with the trope, popular in

circles close to Trump,137 that China is purpose -

fully conducting asymmetric warfare against the

United States through fentanyl flow:

“I mean, China’s fundamentally a state-con -

trolled economy. Do you think that they’re

aware of what’s going on? Or are we sort of

witnessing something like a reverse opium war

where they are intentionally allowing this stuff

[synthetic opioids] to come into our country …

given that China is a largely state-controlled economy and it’s not exactly easy to manu -

facture nitazenes, I wonder if we are looking

at something like a state-sponsor-of-terrorism

argument here, where they are explicitly

permitting a weapon of mass destruction—a

weapon of chemical warfare, effectively—to

enter our country. … China knows that it’s

destabilizing our country, it’s killing our people,

it’s of course doing tremendous damage to our

workforce. And we ought to be looking into

this and really exerting whatever diplomatic

pressure we can on the communist Chinese to

stop this stuff.”138

Throughout the Trump administration, various

activist groups pushed for designating fentanyl

as a weapon of mass destruction (WMD) and

garnered the support of some Republican politi -

cians.139 Such a designation would have complex

and often counterproductive consequences and

would not meaningfully advance international law

enforcement cooperation. Will the Trump admin -

istration pursue it?

No doubt, big gaps persist in China’s law enforce -

ment efforts. The fact that China doesn’t have

material support, conspiracy, and racketeering

statutes means that smugglers selling nonsched -

uled precursors (from which much fentanyl is

still produced) can escape prosecution in China.

These smugglers falsely claim that they do not

know they are selling to Mexican cartels, and as

long as they do not sell scheduled chemicals,

Chinese law enforcement officials do not believe

they can act.140 That China does not demand due

diligence or at least encourage know-your-cus -

tomer practices also allows Chinese officials to

maintain this fiction. The United States has been

pressing on that issue without success.

China badly needs to close those loopholes or

find creative legal and law enforcement ways to

work around them. But Trump’s pardoning of Ross

Ulbricht, whose Silk Road drug smuggling enter -

prise was hardly different from that of Chinese

precursor smugglers, severely undermines

the moral, reputational, legal, and leadership

authority of U.S. demands.141

20  THE FENTANYL  CRISIS: FROM NALOXONE  TO TARIFFSLESSONS FROM PAST PROGRESS

WITH CHINA

If the Trump administration wants to attain

Chinese cooperation on counternarcotics, it

should learn from the Biden administration’s

adroit diplomacy in 2023,142 which led to a

resumption of counternarcotics cooperation

in 2024. As part of that cooperation, China

mounted various measures it had been refusing

to undertake previously. In 2024, a resurrected

U.S.-China counternarcotics working group

began sharing information and intelligence while

Chinese and U.S. law enforcement officers coop -

erated on cases.143 Beijing also scheduled dozens

of fentanyl, xylazine, and nitazenes precursors144

and engaged the chemical industry to discourage

precursor smuggling, sending out notices that

precursor sales would be more tightly monitored

and compliance failures could result in U.S. sanc -

tions and prosecutions.145 China even shut down

what it said were thousands of websites selling

scheduled precursors.146

Those measures were hardly perfect. Chinese

companies sanctioned by the U.S. government

would spring back up online with just a slight

tweak to their name.147 Various journalistic inves -

tigations have revealed that fentanyl precursors

still flow from China.148 But, as discussed earlier,

other such investigations suggested that by the

end of 2024, at least some Mexican fentanyl

cooks were struggling to source traditional

precursors from China.149 This is consistent with

assessments from U.S. government officials and

counternarcotics officers: in interviews with me,

various interlocutors expressed their belief that

considerably fewer precursors were shipped

from China in the second half of 2024 than

before.150

Additionally, a big breakthrough came in the anti-

money laundering (AML) sphere, an area where

China had for some years refused to cooperate

with the United States. Chinese banks, including

the People’s Bank of China, participated in the

U.S.-China fentanyl dialogues. The early 2024

meetings grew into a formal exchange and coop -eration platform between the U.S. Department

of Treasury and the People’s Bank of China.151 As

U.S. law enforcement agencies targeted money

launderers working for the Mexican cartels,152

including Chinese money launderers who have

become the cartels’ to-go money laundering

entities, China cooperated with the United States

in some of the arrests.

Once again, the cooperation, although mean -

ingful, was not without challenges, such as those

stemming from different U.S. and Chinese anti-

money laundering laws. U.S. law enforcement

officials praised China’s creativity in making

charges and indictments consistent with Chinese

laws while being responsive to U.S. requests.153

But in the fall of 2024, Beijing became unhappy

that it hadn’t received the payoffs it expected for

restarting cooperation with Washington—such as

being taken off the United States’ annual “Majors

List” of illicit drug-producing or drug-transit

countries.154 In September 2024, China appeared

on the list for a second time, much to Chinese

officials’ chagrin.155 At the same time, rhetoric in

the United States, especially from Republicans,

linking China to fentanyl precursor flows and U.S.

overdose deaths did not abate despite the new

cooperation.156

Consistent with China’s subordination of law

enforcement cooperation and its denial of law

enforcement cooperation to countries with whom

it has a deteriorating bilateral relationship,157

Chinese government officials explicitly stated

that their country’s counternarcotics cooperation

with the United States would not survive the

imposition of extensive tariffs on China.158 It is to

be expected that China will withdraw from coun -

ternarcotics cooperation if Trump does impose

the 60% tariff on China he has advocated. Such

a tariff would have highly detrimental effects on

the Chinese economy, which is already fragile

from the effects of the COVID-19 pandemic and

China’s policies toward it.159

FOREIGN POLICY AT BROOKINGS 21Although China may eventually become ready

to trade counternarcotics cooperation for tariff

reductions, any extensive tariff on Chinese goods

by the Trump administration will gut cooperation,

rewinding the clock to the 2021-2023 period

when zero cooperation was taking place, making

negotiations to restart it much harder.

Rather than making resorting to tariffs, the Trump

administration should have expressed a strong

commitment to the Global Coalition against the

Threat of Synthetic Drugs, an international forum

built by the Biden administration that became an

important source of leverage with China. However,

due to its indifference to multilateralism, the

Trump administration has not yet committed itself

to sustaining and expanding the coalition’s efforts.

DOMESTIC DRUG POLICY MEASURES

The Trump administration has been slow to

launch domestic fentanyl policies other than

initiating the extensive and brutal roundups and

deportations of undocumented migrants,160 which

the administration framed as a supposed measure

to stop fentanyl trafficking into the United States.

In fact, its orders directing many domestic federal

law enforcement agencies, including the entire

Homeland Security Investigations agency and

parts of the Federal Bureau of Investigations,

and pressure on state and local police forces to

prioritize arresting undocumented migrants risks

diverting attention from disrupting cartel money

laundering and distribution networks in the United

States.161 Deep cuts to federal law enforcement

agencies’ budgets and politically-motivated

purges will only worsen the reductions in law

enforcement resources.

Trump’s recent rhetoric regarding domestic

drug policies has been dramatic and suggests

a substantial departure from some of the first

Trump administration’s policies. In October 2017,

the first Trump administration declared the opioid

epidemic a health emergency but did not provide

a much-needed boost in funding for necessary

policy responses.162 A year later, however, in

October 2018, the U.S. Congress passed a signif -icant piece of legislation with bipartisan support:

the SUPPORT Act.163 The act, which expired

in October 2023, allocated federal funds for

prevention, treatment, education, medical insur -

ance, and law enforcement programs pertaining

to the opioid crisis. It provided additional funding

for community-based treatment and recovery

programs through grants administered by the

Department of Labor and required Medicaid

to cover the three medications for opioid

use disorder approved by the Food and Drug

Administration. It also sought to standardize the

delivery of medicine and treatment for substance

use disorders and to mitigate the impact of the

opioid epidemic on the U.S. workforce.

Moreover, and importantly, the Trump adminis -

tration did not significantly interfere with various

forms of policy experimentation at the local level,

such as increasing the availability of naloxone.

In fact, policy moves toward evidence-based

treatment modalities and even harm-reduction

approaches expanded even in some conservative

Republican jurisdictions.

The second time around, Trump has assumed

the presidency with strongly formed views on

various aspects of U.S. drug policy. Since Trump

did not like the policy recommendations of the

blue-ribbon commission he set up during his first

term to study the opioid and fentanyl crises and

only reluctantly followed them, he has refused

to appoint another expert panel: “No more

blue-ribbon,” he repeatedly stated during his

campaign. “I refuse to create them anymore.”164

Beyond permanently scheduling all fentanyl

analogs in the United States,165 Trump’s core

proposition for addressing the fentanyl crisis has

been to impose the death penalty for all drug

dealing, an unprecedented step in U.S. criminal

justice: “Every drug dealer, during his or her life

on average will kill 500 people with the drugs

they sell, not to mention the destruction of the

families,” Trump asserted in November 2022.166

“But we’re going to be asking everyone who sells

drugs, gets caught, to receive the death penalty

for their heinous acts.”167

22  THE FENTANYL  CRISIS: FROM NALOXONE  TO TARIFFSImposing the death penalty on drug traffickers

has not eliminated drug trafficking anywhere

in the world; in fact, some countries with the

highest rates of execution for drug-related

matters have seen an intensification of drug use

and trafficking. Saudi Arabia, for example, has

been reeling from intensively augmented drug

use and far greater and more dangerous drug

flows than ever before.168 Any move by the U.S.

criminal justice system to impose the death

penalty for drug dealing would not only be brutal

and woefully ineffective but would also under -

mine the effects of life-saving Good Samaritan

laws in the United States, which Neil and Kilmer

highlight as positive innovations in their paper on

domestic drug enforcement in this series.169

But even short of imposing the death penalty,

the FTO designation of Mexican cartels now

allows the Trump administration to charge street

drug dealers with terrorism charges either for

membership reasons or under material support

clauses even if the dealers do not belong to

any of the designated groups. This could lead

to lengthy imprisonment for users, returning

U.S. policies to the misguided approaches seen

during the height of the War on Drugs in the late

1980s and early 1990s. In fact, even nonviolent

drug users could be charged under the material

support clauses.170 That would be an even worse

development, discouraging users from seeking

out medical treatment and other important

support or perhaps even purchasing overdose

medications such as naloxone.

Of course, the Trump administration will exer -

cise discretion in whom it prosecutes under the

terrorism clauses, which could—and absolutely

should—spare users such charges. But the

designation nonetheless opened up a dangerous

slippery slope and massive legal headaches for

delivering treatment and assistance and appro -

priately responding to domestic drug markets.

Even before that designation took place, Trump

already planned to toughen U.S. domestic drug

enforcement. He promised to direct U.S. federal

agencies to take down gangs and other street-crime organizations that distribute drugs at the

local level,171 in what appears to be an echo of his

preoccupation with the Mara Salvatrucha, known

as MS-13, gang during his first presidency.172

In its Project 2025, the Heritage Foundation, a

think tank closely linked to Trump, argued for

sharply increasing arrests made for mere drug

possession.173 Although Trump tried to distance

himself from Project 2025 during the last stages

of his campaign,174 this idea, as well as the idea

of tougher penalties for drug possession, has

gained traction with conservative politicians.175

Yet decades of evidence, highlighted by various

papers in this series, show that extensive arrests

for drug possession and low-level drug dealing

are ineffective and counterproductive policies,

saddling states and the federal government

with the massive economic and social costs of

incarceration while compounding substance use

disorders. It took decades of painful drug policy

experiences for the United States to ease away

from such policies.

However, the extent to which the Trump admin -

istration can redirect law enforcement agencies

toward cracking down on nonviolent users is not

clear-cut. Most street-level law enforcement in

the United States is handled by states and coun -

ties and not the federal government. Increasing

arrests for users may find traction in jurisdictions

aligned with Trump’s ideology, but even those

jurisdictions will be aware of the enormous costs

associated with high incarceration levels. What is

more, law enforcement resources in many areas

will need to be diverted to rounding up undoc -

umented migrants. The Trump administration

can incentivize state and local law enforcement

to follow its policy preferences by awarding

financial grants and imposing penalties, many of

which depend on federal financial transfers.176

But states and counties will still have a lot of say

in how local law enforcement is used against

dealers and users of fentanyl.

A milder version of the law enforcement

approach to users could center on expanding

police-led diversion programs that allow users

to avoid incarceration. This would be especially

FOREIGN POLICY AT BROOKINGS 23important were the Trump administration to

pull back from the already inadequate provision

of buprenorphine and methadone in jails and

prisons by restricting federal funding, including

Medicaid coverage.177

If the Affordable Care Act were to be revoked

or significantly altered, insurance coverage for

treating substance use disorders could decrease

or altogether collapse for many. Yet as LaBelle

and Holtgrave and Gastala, Pollack, et al. write

in their respective papers, insurance coverage is

crucial for expanding access to treatment.178

Though Trump and Vance have advocated for

a number of harsh, militarized, and counterpro -

ductive policies, they have also voiced support

for some public health and harm-reduction

approaches toward drug users. For example,

while disavowing decriminalization and linking it

to high overdose-death and addiction rates in the

Pacific Northwest, Vance, whose own mother has

struggled with a substance use disorder, argued:

“Look—some harm reduction absolutely

matters, right? Suboxone to sort of medically

assisted treatment for people who are trying

to break clean of this stuff [substance use

disorder]—all that’s part of the equation, but

I think that if we believe we’re going to solve

the opioid problem by handing out needles,

we’re going to make the problem worse.

Legalization is not going to help, but maybe

doing medically assisted treatment more and

making that more accessible, that’s a good

solution.”179

Indeed, there is strong bipartisan interest in

preserving access to buprenorphine and metha -

done.180

Yet some scaling back of federal support for

evidence-based treatment and harm-reduction

approaches appears likely—whether it takes

place under budget cuts led by Elon Musk

and his so-called Department of Government

Efficiency, from the administration’s possible

changes to Medicaid and insurance coverage, or from Trump’s ban on DEI efforts.181 Minority and

underprivileged communities were experiencing

the highest fentanyl-linked mortality even before

the DEI ban went into effect, and they now may

find it even more difficult to access overdose-re -

versing or effective treatment medication.182

Moreover, it is not clear to what extent preven -

tion and treatment programs supported by the

Trump administration will center on evidence-

based medical interventions, as opposed to

ideological notions of abstinence. Trump, for

example, promised to “make it easier for those

suffering from addiction to seek treatment

without losing their job,” and to “strengthen the

pillars that give life meaning and hope for those

struggling with addiction—in particular work,

faith, and family.”183 The secretary of Health and

Human Services, Robert F. Kennedy, Jr., who

himself suffered from heroin use disorder, is

known to promote abstinence and work-based

treatment approaches, such as so-called healing

farms.184 Some of the healing farms outright ban

medication for fentanyl and other substance use

disorders; few, if any, have a strongly evaluated

proven record of effectiveness.185 Diverting

resources and focus away from overdose

prevention or funding poorly designed and run

programs that do not operate with qualified staff

and do not employ evidence-based approaches

will bring about a rapid reescalation in mortality.

Baltimore can serve as an example.186 When the

city’s health authorities paid close attention to

the fentanyl crisis, specifically sought to reach

the most vulnerable communities, and appropri -

ately resourced their fentanyl efforts, mortality

remained low. When attention and resources

were shifted elsewhere, mortality shot up.187

How the balance between ideology- and

evidence-based policies and interventions will

turn out in the Trump administration remains

to be seen. In its Project 2025, the Heritage

Foundation argued that “it is imperative that

a political appointee lead the ONDCP [Office

of National Drug Control Policy] budget office

… [and that] grant programs are funding the

President’s drug control priorities and not woke

24  THE FENTANYL  CRISIS: FROM NALOXONE  TO TARIFFSnonprofits with leftist policy agendas.”188 Such

statements indicate a desire within the Trump

administration to roll back at least some treat -

ment and harm-reduction modalities and to

decrease interagency coordination and strate -

gizing.

Conclusions

It is crucial that U.S. drug strategies—and,

indeed, all matters of public policy—be informed

by facts and evidence, as opposed to ideolog -

ical stances or philosophical frameworks. In the

United States and Canada, tens of thousands

of lives per year, not to mention the countries’

economies and workforces, continue to be at

stake. Fentanyl use is spreading in Mexico,

where Mexican cartels produce essentially the

entire supply that enters the United States using

precursor chemicals sourced in China and India.

The economic threat posed by fentanyl in Mexico

is augmented by the tremendous, and expanding,

power of Mexican criminal groups.

Recent reductions in opioid overdoses in the

United States are most welcome, but these

improvements could easily be reversed. New

rays of hope could easily be clouded over. While

much remains unclear about what has driven

recent declines in overdose death rates, there is

widespread consensus about the effectiveness

and importance of certain policies. As indicated

in the Brookings series “The fentanyl epidemic in

North America and the global reach of synthetic

opioids,” it is crucial to achieve and maintain

widespread access to evidence-based interven -

tions such as overdose-reversal medication and

medication-based treatment regimens for opioid

use disorder, the feasibility of which, especially in

the case of the latter, is dependent on expanding

medical insurance coverage for those with

substance use disorders.Effectively managing the international supply of

drugs is also important. Yet the proposed tariffs

on China—both the general and the fentan -

yl-specific tariffs—are likely to set significantly

set back or again lead to the suspension of

China’s counternarcotics. Maintaining the adroit

diplomacy the Biden administration exhibited

during 2023 and 2024 vis-à-vis China and

fentanyl and using it as a basis for deepening

cooperation and addressing outstanding issues in

the bilateral relationship would be a more fruitful

approach. In the case of Mexico, the threat of

a 25% fentanyl-linked tariff could actually stim -

ulate meaningful cooperation against Mexican

cartels and organized crime, something that

was woefully lacking during the López Obrador

administration. The Sheinbaum administration

is more interested in combatting organized

crime. But any gains from the tariff threat will

only be realized if the United States pursues

the right objectives, doesn’t subordinate anti-

crime measures to migration control, and doesn’t

explode the relationship by resorting to unilateral

military actions in Mexico.

Seeking to inform policymakers as well as the

broader public, the Brookings fentanyl series,

of which this paper is part, provides important

insights into these issues and many other dimen -

sions of U.S. drug policy at home and abroad.

In-depth papers and a podcast series, The Killing

Drugs,189 provide lessons and recommendations

to policymakers in the United States and beyond

for confronting the immense risks and harms

generated by synthetic opioids and other potent

synthetic drugs.

Endnotes

1 “Fact Sheet: President Donald J. Trump

Imposes Tariffs on Imports from Canada,

Mexico and China,” The White House,

February 1, 2025, https://www.whitehouse.

gov/fact-sheets/2025/02/fact-sheet-pres -

ident-donald-j-trump-imposes-tariffs-on-

imports-from-canada-mexico-and-china/ .

2 John Ruwitch, “Chinese countertariffs to

kick in as Trump threatens more to come,”

NPR, February 10, 2025, https://www.npr.

org/2025/02/10/nx-s1-5292017/china-tar -

iffs-us-retaliation-trump .

3 David Lawder and Andrea Shalal, “Trump

triggers trade war with tariffs on Canada,

China and Mexico,” Reuters, March 4,

2025, https://www.reuters.com/world/

trade-wars-erupt-trump-hits-canada-mex -

ico-china-with-steep-tariffs-2025-03-04/ .

4 Based on data from “Drug overdose

deaths in the United States, 2002-2022,”

(Bethesda, MD: National Center for Health

Statistics, 2023), https://www.cdc.gov/

nchs/data/databriefs/db491-tables.pdf .

5 Josh Boak, “Trump says Americans

could feel ‘some pain’ from his new

tariffs that are triggering a trade war,”

The Associated Press, February 2,

2025, https://apnews.com/article/

trump-tariffs-canada-mexico-chi -

na-trade-surplus-3010e6368545e2976fe -

b5ac6b41e528e .

6 Costas Pitas, “Trump vows new Canada,

Mexico, China tariffs that threaten global

trade,” Reuters, November 26, 2024,

https://www.reuters.com/world/us/

trump-promises-25-tariff-products-mexi -

co-canada-2024-11-25/ .

7 Julieta Contreras et al., “The future of the

USMCA: What’s next for US trade rela -

tions with Canada and Mexico?” Peterson

Institute for International Economics, January 30, 2025, https://www.piie.

com/microsites/2025/future-usmca ; Ana

Swanson, “Trump Is Said to Push for Early

Reopening of North American Trade Deal,”

The New York Times , January 21, 2025,

https://www.nytimes.com/2025/01/21/

business/economy/trump-usmca-trade-

deal-mexico-canada-autos.html .

8 “The fentanyl epidemic in North America

and the global reach of synthetic opioids,”

The Brookings Institution, December 2024,

https://www.brookings.edu/collection/

the-fentanyl-epidemic-in-north-ameri -

ca-and-the-global-reach-of-synthetic-opi -

oids/ .

9 “Justice Department Announces

Global Resolution of Criminal and Civil

Investigations with Opioid Manufacturer

Purdue Pharma and Civil Settlement

with Members of the Sackler Family,”

U.S. Department of Justice, October 21,

2020, https://www.justice.gov/opa/pr/

justice-department-announces-glob -

al-resolution-criminal-and-civil-investiga -

tions-opioid .

10 For a review of the history, see Keith

Humphreys, Jonathan P. Caulkins, and

Vanda Felbab-Brown, “Opioids of the

Masses: Stopping an American Epidemic

from Going Global,” Foreign Affairs , May/

June 2018, https://www.foreignaffairs.com/

articles/world/2018-04-16/opioids-masses ;

Vanda Felbab-Brown et al., “Overview: The

U.S. Opioid Crisis in America,” (Washington,

DC: The Brookings Institution, June 22,

2020), https://www.brookings.edu/articles/

the-opioid-crisis-in-america-domes -

tic-and-international-dimensions/; and

Jonathan P. Caulkins and Keith Humphreys,

“Preventing opioid misuse and addiction:

New thinking and the latest evidence,”

(Washington, DC: The Brookings Institution,

June 2020), https://www.brookings.edu/

articles/preventing-opioid-misuse-and-ad -

diction-new-thinking-and-the-latest-evi -

dence/ .

11 Vanda Felbab-Brown, “Fending Off

Fentanyl and Hunting Down Heroin:

Suppressing Opioid Supply from Mexico,”

(Washington, DC: The Brookings Institution,

July 22, 2020), https://www.brookings.edu/

articles/fending-off-fentanyl-and-hunting-

down-heroin-suppressing-opioid-supply-

from-mexico/ .

12 “Fentanyl,” Drug Enforcement

Administration, https://www.dea.gov/fact -

sheets/fentanyl .

13 Vanda Felbab-Brown, “Addressing Mexico’s

Role in the U.S. Fentanyl Epidemic,”

(Washington, DC: The Brookings

Institution, July 19, 2023), https://www.

brookings.edu/articles/addressing-mexi -

cos-role-in-the-us-fentanyl-epidemic/ .

14 Vanda Felbab-Brown, “China and

Synthetic Drugs Control: Fentanyl,

Methamphetamines, and Precursors,”

(Washington, DC: The Brookings Institution,

March 2022), https://www.brookings.edu/

articles/china-and-synthetic-drugs-con -

trol-fentanyl-methamphetamines-and-pre -

cursors/ .

15 “Justice Department Announces

Charges Against Sinaloa Cartel’s Global

Operation,” U.S. Department of Justice,

April 14, 2023, https://www.justice.gov/

opa/pr/justice-department-announc -

es-charges-against-sinaloa-cartel-s-glob -

al-operation .

16 Greg Midgette and Peter Reuter, “The

Dynamics of U.S. Drug Markets,”

(Washington, DC: The Brookings Institution,

December 2024), https://www.brookings.

edu/articles/the-dynamics-of-us-drug-

markets/ .

17 Ibid.18 Jan Hoffman, “Tranq Dope: Animal

Sedative Mixed with Fentanyl Brings Fresh

Horror to U.S. Drug Zones,” The New York

Times , January 7, 2023, https://www.

nytimes.com/2023/01/07/health/fentan -

yl-xylazine-drug.html .

19 “DEA and DHS Issue Joint Update

on Sources of Illicit Xylazine,” Drug

Enforcement Administration, September

22, 2023, https://www.dea.gov/

stories/2023/2023-09/2023-09-22/

dea-and-dhs-issue-joint-update-sources-

illicit-xylazine .

20 “Biden-Harris Administration Designates

Fentanyl Combined with Xylazine as an

Emerging Threat to the United States,”

Office of National Drug Control Policy,

April 12, 2024, https://www.whitehouse.

gov/ondcp/briefing-room/2023/04/12/

biden-harris-administration-desig -

nates-fentanyl-combined-with-xyla -

zine-as-an-emerging-threat-to-the-unit -

ed-states/#:~:text=ATLANTA%2C%20

GA%20%E2%80%93%20Today%2C%20

Dr,threat%20to%20the%20United%20

States .

21 Alison Athey, Beau Kilmer, and Julie Cerel,

“An Overlooked Emergency: More Than

One in Eight US Adults Have Had Their

Lives Disrupted by Drug Overdose Deaths,”

American Journal of Public Health 114, no.

3, (March 2024): 276-279, https://ajph.

aphapublications.org/doi/abs/10.2105/

AJPH.2023.307550 .

22 “The Full Cost of the Opioid Crisis: $2.5

Trillion Over Four Years,” The White House,

October 28, 2019, https://www.white -

house.gov/articles/full-cost-opioid-crisis-

2-5-trillion-four-years/ .

23 “The Economic Toll of the Opioid Crisis

Reached Nearly $1.5 Trillion in 2020,”

(Washington, DC: U.S. Senate, Joint

Economic Committee, 2022), http://gasps -

data.net/data/economic-toll-opioid-crisis-

reached-nearly-15-trillion-2020 .

24 Nicole Gastala, Harold Pollack, et

al., “Expanding Access to Addiction

Treatment,” (Washington, DC: The

Brookings Institution, December 2024),

https://www.brookings.edu/articles/

expanding-access-to-addiction-treat -

ment/ .

25 Philomena Kebec, “The Impact of Fentanyl

on American Indian and Alaskan Native

Communities,” (Washington, DC: The

Brookings Institution, December 2024),

https://www.brookings.edu/articles/

the-impact-of-fentanyl-on-american-indi -

an-and-alaskan-native-communities/ .

26 “U.S. Overdose Deaths Decrease in 2023,

First Time Since 2018,” (Bethesda, MD:

National Center for Health Statistics,

May 15, 2024), https://www.cdc.

gov/nchs/pressroom/nchs_press_

releases/2024/20240515.htm .

27 Ibid.

28 Ibid.

29 F.B. Ahmad et al., “Provisional drug over -

dose death counts,” (Bethesda, MD:

National Center for Health Statistics,

October 17, 2024), https://www.cdc.gov/

nchs/nvss/vsrr/drug-overdose-data.htm ;

Noah Weiland, “Fatal Drug Overdoses

Are Dropping. Not Everyone Is Spared.”

The New York Times , October 25, 2024,

https://www.nytimes.com/2024/10/25/us/

drug-overdoses-opioids-fentanyl.html .

30 Brian Mann, “NPR Exclusive: U.S. overdose

deaths plummet, saving thousands of

lives,” NPR, September 18, 2024, https://

www.wesa.fm/2024-09-18/npr-exclusive-

u-s-overdose-deaths-plummet-saving-

thousands-of-lives.

31 Jan Hoffman and Noah Weiland, “What’s

Behind the Remarkable Drop in U.S.

Overdose Deaths,” The New York Times ,

November 21, 2024, https://www.nytimes.

com/2024/11/21/health/overdose-

deaths-decline-drug-supply.html ; David

R. Holtgrave, Allan Clear, and James V. McDonald, “Public health implications of

recent declines in fatal drug overdoses in

New York State and the United States,”

Health Affairs Scholar 2, no. 12 (December

2024), https://academic.oup.com/healthaf -

fairsscholar/article/2/12/qxae172/7922309 .

32 Nabarun Dasgupta, Colin Miller, and Adams

Sibley, “Are Overdoses Down and Why?”

Opioid Data Lab, September 18, 2024,

https://opioiddatalab.ghost.io/are-overdos -

es-down-and-why/ .

33 “One Pill Can Kill,” Drug Enforcement

Administration, https://www.dea.gov/

onepill .

34 Jan Hoffman and Noah Weiland, “What’s

Behind the Remarkable Drop in U.S.

Overdose Deaths.”

35 Vanda Felbab-Brown’s interview with a first

responder in upstate New York, December

2024.

36 “Lifesaving Naloxone,” Centers for Disease

Control and Prevention, https://www.

cdc.gov/stop-overdose/caring/naloxone.

html#:~:text=Naloxone%20is%20avail -

able%20in%20all%2050%20states%20

and%20over%20the%20counter .

37 Nabarun Dasgupta, Colin Miller, and Adams

Sibley, “Are Overdoses Down and Why?”

38 “The Growing Threat of Xylazine and

Its Mixture with Illicit Drugs,” Drug

Enforcement Administration, https://

www.dea.gov/sites/default/files/2022-12/

The%20Growing%20Threat%20of%20

Xylazine%20and%20its%20Mixture%20

with%20Illicit%20Drugs.pdf .

39 Shannon M. Casillas et al., “Estimating

the ratio of fatal to non-fatal overdoses

involving all drugs, all opioids, synthetic

opioids, heroin or stimulants, USA,

2010-2020,” Injury Prevention 30, no. 2

(2024), https://injuryprevention.bmj.com/

content/30/2/114 .

40 See Daniel Rosenblum et al., “Estimating

changes in overdose death rates from

increasing methamphetamine supply

in Ohio: Evidence from crime lab data,”

Drug and Alcohol Dependence Reports 11

(June 2024), https://pubmed.ncbi.nlm.nih.

gov/38745681/ ; Jan Hoffman and Noah

Weiland, “What’s behind the remarkable

drop in U.S. overdose deaths.”

41 Greg Midgette and Peter Reuter,

“The dynamics of US drug markets,”

(Washington, DC: The Brookings Institution,

December 2024), https://www.brookings.

edu/articles/the-dynamics-of-us-drug-

markets/ .

42 Vanda Felbab-Brown, “The Middle East

Is Awash in Drugs,” Foreign Affairs , April

11, 2024, https://www.foreignaffairs.com/

middle-east/middle-east-awash-drugs ;

Vanda Felbab-Brown, “The Foreign Policies

of the Sinaloa Cartel and CJNG—Part V:

Europe’s Supercoke & on-the-Horizon

Issues and the Middle East,” Mexico Today,

September 16, 2022, https://mexicotoday.

com/2022/09/16/opinion-the-foreign-

policies-of-the-sinaloa-cartel-and-cjng-

part-v-europes-supercoke-on-the-hori -

zon-issues-and-the-middle-east/ ; Vanda

Felbab-Brown, “The Foreign Policies of the

Sinaloa Cartel and CJNG—Part IV: Europe’s

Cocaine and Meth Markets,” Mexico Today,

September 2, 2022, https://mexicotoday.

com/2022/09/02/opinion-the-foreign-pol -

icies-of-the-sinaloa-cartel-and-cjng-part-

iv-europes-cocaine-meth-markets/ .

43 Brian Mann, “The pipeline of deadly

fentanyl into the U.S. may be drying up,

experts say,” NPR, October 1, 2024, https://

www.npr.org/2024/09/30/nx-s1-5124997/

fentanyl-overdose-opioid-btmps-drug-

cartel-xylazine-tranq-mexico-china .

44 “DEA’s Third Annual National Family

Summit on Fentanyl Highlights

Progress in Fight to Save Lives,” Drug

Enforcement Administration, November

15, 2024, https://www.dea.gov/press-re -leases/2024/11/15/deas-third-annu -

al-national-family-summit-fentanyl-high -

lights-progress .

45 Brian Mann, “The pipeline of deadly

fentanyl into the U.S.”; Anne Milgram,

“Statement of Anne Milgram Administrator

at a Hearing Entitled Oversight of the

Drug Enforcement Administration,”

House Subcommittee on Crime and

Federal Government Surveillance, July

27, 2023, https://www.dea.gov/docu -

ments/2023/2023-07/2023-07-27/state -

ment-anne-milgram-administrator-hear -

ing-entitled-oversight .

46 Brian Mann, “The pipeline of deadly

fentanyl into the U.S.”

47 Vanda Felbab-Brown, “China, Mexico,

and America’s fight against the fentanyl

epidemic,” The Brookings Institution,

March 20, 2024, https://www.brookings.

edu/articles/china-mexico-and-ameri -

cas-fight-against-the-fentanyl-epidemic/;

Vanda Felbab-Brown, “US-China Relations

and Fentanyl and Precursor Cooperation in

2024,” The Brookings Institution, February

29, 2024, https://www.brookings.edu/

articles/us-china-relations-and-fentan -

yl-and-precursor-cooperation-in-2024/ .

48 Deidre McPhillips, “Less-potent fentanyl

pills may be playing a role in decrease of

US overdose deaths, DEA says,” CNN,

November 21, 2024, https://www.cnn.

com/2024/11/21/health/fentanyl-pills-

less-potent-dea-overdose-deaths/

index.html ; Nabarun Dasgupta, “Peak OD

Phenotypes,” Opioid Data Lab, University

of North Carolina at Chapel Hill, February

12, 2025, https://opioiddatalab.ghost.io/

peak-od-phenotypes/ .

49 Vanda Felbab-Brown, “US-China Relations

and Fentanyl and Precursor Cooperation in

2024.”

50 Jan Hoffman and Noah Weiland, “What’s

Behind the Remarkable Drop in U.S.

Overdose Deaths.”

51 Vanda Felbab-Brown’s interviews with

Chinese government officials, November

2024.

52 Natalie Kitroeff and Paulina Villegas,

“How Mexican Cartels Test Fentanyl on

Vulnerable People and Animals,” The New

York Times , December 26, 2024, https://

www.nytimes.com/2024/12/26/world/

americas/mexican-cartels-test-fentanyl.

html.

53 Maurice Tamman, Laura Gottesdiener, and

Stephen Eisenhammer, “We bought every -

thing needed to make $3 million worth of

fentanyl. All it took was $3,600 and a web

browser,” Reuters, July 25, 2024, https://

www.reuters.com/investigates/special-re -

port/drugs-fentanyl-supplychain/ . See

also Steven Dudley et al., “The Flow of

Precursor Chemicals for Synthetic Drug

Production in Mexico,” InSight Crime, May

2023, https://insightcrime.org/wp-content/

uploads/2023/05/The-Flow-of-Precursor-

Chemicals-for-Synthetic-Drug-Production-

in-Mexico-InSight-Crime-March-2023-3.

pdf.

54 Jonathan P. Caulkins, “How Should Drug

Policy Respond to Surging Supplies of

Dangerous Drugs,” (Washington, DC: The

Brookings Institution, December 2024),

https://www.brookings.edu/articles/

how-should-drug-policy-respond-to-surg -

ing-supplies-of-dangerous-drugs/ .

55 “World Drug Report 2024,” (Vienna: United

Nations Office on Drugs and Crime, June

2024), https://www.unodc.org/unodc/

en/data-and-analysis/world-drug-re -

port-2024.html .

56 Vanda Felbab-Brown, Jonathan P. Caulkins,

and Keith Humphreys, “How Synthetic

Opioids Can Radically Change and Its

International Relations Implications,” The

Brookings Institution, May 2018, https://

www.brookings.edu/articles/how-synthet -

ic-opioids-can-radically-change-global-il -

legal-drug-markets-and-foreign-policy/. 57 “Fifth Annual Meeting of the U.S.-India

Counternarcotics Working Group,” Office of

National Drug Control Policy, October 24,

2024, https://www.whitehouse.gov/ondcp/

briefing-room/2024/10/24/fifth-annual-

meeting-of-the-u-s-india-counternarcot -

ics-working-group/ .

58 Natalie Kitroeff and Paulina Villegas,

“Mexican Cartels Lure Chemistry Students

to Make Fentanyl,” The New York Times ,

December 1, 2024, https://www.nytimes.

com/2024/12/01/world/americas/mexi -

co-fentanyl-chemistry-students.html .

59 “National Drug Threat Assessment 2024,”

Drug Enforcement Administration, May

2024, dea.gov/sites/default/files/2024-

05/5.23.2024 NDTA-updated.pdf .

60 “El Chapo’s sons bar fentanyl production

in Sinaloa, according to banners,” Reuters,

October 3, 2023, https://www.reuters.com/

world/americas/el-chapos-sons-ban-fen -

tanyl-production-sinaloa-according-ban -

ners-2023-10-03/ ; Parker Asmann, Victoria

Dittmar, and Peter Appleby, “Mexico

Fentanyl Production Migrates North as

Chapitos Death Threats Loom,” InSight

Crime, March 18, 2024, https://insight -

crime.org/news/mexico-fentanyl-produc -

tion-migrates-chapitos-death-threats/ .

61 Vanda Felbab-Brown’s interviews with

Sinaloa-based journalists, academics,

nongovernmental organization activ -

ists, and government officials, Culiacán,

November 2023.

62 “National Drug Threat Assessment 2024,”

Drug Enforcement Administration, 23.

63 Deidre McPhillips, “Less-potent fentanyl

pills may be playing a role.”

64 Natalie Kitroeff and Paulina Villegas,

“Mexican Cartels Lure Chemistry

Students.”

65 Vanda Felbab-Brown, “The Sinaloa Cartel

Arrests: Stunning Tactical Success,

Strategic Blunder?” The Brookings

Institution, July 26, 2024, https://www.

brookings.edu/articles/the-sinaloa-car -

tel-arrests-stunning-tactical-success-stra -

tegic-blunder/ ; Natalie Kitroeff and Paulina

Villegas, “A Cartel Double-Cross Turns a

Mexican State into a War Zone,” The New

York Times , October 8, 2024, https://www.

nytimes.com/2024/10/08/world/americas/

mexico-sinaloa-cartel-war.html .

66 Jennifer Martinez, Regina LaBelle, and

Shelly Weizman, “Examining Overdose

Inequities: 2022-23 Data,” O’Neill Institute,

Georgetown University Law School,

November 12, 2024, https://oneill.law.

georgetown.edu/examining-overdose-in -

equities-2022-23-data/ ; Noah Weiland,

“Fatal Drug Overdoses Are Dropping. Not

Everyone Is Spared.”

67 Ibid.

68 Ibid.

69 Nicole Gastala, Harold Pollack, et

al., “Expanding Access to Addiction

Treatment”; Regina LaBelle and David

Holtgrave, “Harm Reduction and Its Role

in Improving Health Outcomes in an

Era of Fentanyl,” (Washington, DC: The

Brookings Institution, December 2024),

https://www.brookings.edu/wp-content/

uploads/2024/11/FP-20241127-harm-

reduction-labelle-holtgrave.pdf ; and

Philomena Kebec, “The Impact of Fentanyl

on American Indian and Alaskan Native

Communities.”

70 Erica Green, “U.S. Orders Federal D.E.I.

Efforts to Shut Down by Wednesday Night,”

The New York Times , January 22, 2025,

https://www.nytimes.com/2025/01/22/us/

politics/trump-dei-diversity-officials-or -

ders.html .

71 “Comprehensive Addiction and Recovery

Act of 2016,” Pub. L. No. 114-198, 130

Stat. 695 (2016), https://www.congress.gov/bill/114th-congress/senate-bill/524/

text; “21st Century Cures Act,” Pub. L.

114-255, 130 Stat. 1033 (2016), https://

www.congress.gov/bill/114th-congress/

house-bill/34 ; “SUPPORT for Patients and

Communities Act,” Pub. L. 115-271, 132

Stat. 3894 (2018), https://www.congress.

gov/bill/115th-congress/house-bill/6 ;

“Rural Opioid Abuse Prevention Act,”

Pub. L. 117-250, 136 Stat. 2352 (2022),

https://www.congress.gov/bill/117th-con -

gress/senate-bill/2796 ; “James M. Inhofe

National Defense Authorization Act for

Fiscal Year 2023,” Pub. L. 117-263, 136

Stat. 2395 (2022), https://www.congress.

gov/bill/117th-congress/house-bill/7776/

text; “END FENTANYL Act,” Pub. L.

118-43, 138 Stat. 453 (2024), https://

www.congress.gov/bill/118th-congress/

senate-bill/206 ; and “Making emergency

supplemental appropriations for the fiscal

year ending September 30, 2024, and for

other purposes,” H.R. 815, Pub. L. 118-50,

138 Stat. 895, https://www.congress.gov/

bill/118th-congress/house-bill/815 .

72 “The Biden-Harris Administration’s

Statement of Drug Policy Priorities for

Year One,” Office of National Drug Control

Policy, April 1, 2021, https://www.white -

house.gov/wp-content/uploads/2021/03/

BidenHarris-Statement-of-Drug-Policy-

Priorities-April-1.pdf?fbclid=IwAR2TBk34U_

XRqlqK_pAYnUd_9f7zY3IbCQI9KxI6S5eY -

eRJdFzl9B09hZ84 .

73 Sharon Otterman, “Federal Officials May

Shut Down Overdose Prevention Centers

in Manhattan,” The New York Times ,

August 8, 2023, https://www.nytimes.

com/2023/08/08/nyregion/drug-overdos -

es-supervised-consumption-nyc.html .

74 Rahul Gupta et al., “Transforming

Management of Opioid Use Disorder with

Universal Treatment,” New England Journal

of Medicine 387, no. 15 (September 2022):

1341-1344, https://www.nejm.org/doi/

full/10.1056/NEJMp2210121 .

75 “Key Substance Use and Mental Health

Indicators in the United States: Results

from the 2022 National Survey on Drug

Use and Health,” Substance Abuse and

Mental Health Services Administration,

November 2023, https://www.samhsa.

gov/data/sites/default/files/reports/

rpt42731/2022-nsduh-nnr.pdf .

76 Nicole Gastala, Harold Pollack, et

al., “Expanding Access to Addiction

Treatment”; and Philomena Kebec, “The

Impact of Fentanyl on American Indian and

Alaskan Native Communities.”

77 Keith N. Humphreys, “The Rise and

Fall of Pacific Northwest Drug Policy

Reform, 2020-2024,” The Brookings

Institution, December 2024, https://www.

brookings.edu/articles/the-rise-and-fall-

of-pacific-northwest-drug-policy-re -

form-2020-2024/ .

78 Roland Neil and Beau Kilmer, “Criminal

Legal Interventions During the Overdose

Crisis: Noteworthy Trends and Policy

Changes,” (Washington, DC: The Brookings

Institution, December 2024), https://www.

brookings.edu/articles/criminal-justice-in -

terventions-during-the-overdose-crisis/ .

79 “Safer Supply: Prescribed medications as

a safer alternative to toxic illegal drugs,”

Government of Canada, April 25, 2023,

https://www.canada.ca/en/health-canada/

services/opioids/responding-canada-opi -

oid-crisis/safer-supply.html ; “Prescribed

Safer Supply: Frequently Asked Questions,”

National Safer Supply Community of

Practice, https://www.substanceuseh -

ealth.ca/pss-faq#:~:text=They%20

prescribe%20oral%20hydromorphone%20

(Dilaudid,and%20improves%20quality%20

of%20life .

80 Jonathan P. Caulkins, “How Should Drug

Policy Respond to Surging Supplies of

Dangerous Drugs.”81 “Joint Statement from the Co-Chairs of

the Special Advisory Committee on Toxic

Drug Poisonings—Latest National Data

on Substance-Related Harms,” Public

Health Agency of Canada, June 28, 2024,

https://www.canada.ca/en/public-health/

news/2024/06/joint-statement-from-the-

co-chairs-of-the-special-advisory-commit -

tee-on-toxic-drug-poisonings--latest-na -

tional-data-on-substance-related-harms.

html.

82 Vanda Felbab-Brown, “China, Mexico,

and America’s fight against the fentanyl

epidemic.”

83 Vanda Felbab-Brown, “Prospects and

Possibilities for US-Mexico Security

Cooperation during the Sheinbaum

Administration,” (Washington, DC:

Woodrow Wilson International Center for

Scholars, December 20, 2024), https://

www.wilsoncenter.org/publication/pros -

pects-and-possibilities-us-mexico-securi -

ty-cooperation-during-sheinbaum .

84 Josh Boak, “Trump says Americans could

feel ‘some pain’ from his new tariffs.”

85 David Lawder and Andrea Shalal, “Trump

triggers trade war with tariffs on Canada,

China and Mexico,” Reuters, March 4,

2025, https://www.reuters.com/world/

trade-wars-erupt-trump-hits-canada-mex -

ico-china-with-steep-tariffs-2025-03-04/ .

86 “Designating Cartels And Other

Organizations As Foreign Terrorist

Organizations And Specially Designated

Global Terrorists: Executive Order,”

The White House, January 20,

2025, https://www.whitehouse.

gov/presidential-actions/2025/01/

designating-cartels-and-other-orga -

nizations-as-foreign-terrorist-organiza -

tions-and-specially-designated-global-ter -

rorists/ .

87 “President Donald J. Trump Declares War

on Cartels,” Donald J. Trump, December

22, 2023, https://www.donaldjtrump.com/

agenda47/president-donald-j-trump-de -

clares-war-on-cartels .

88 See, for example, Joel Rose, “Who is

sneaking fentanyl across the southern

border? Hint: It’s not the migrants,”

NPR, August 9, 2023, https://www.npr.

org/2023/08/09/1191638114/fentan -

yl-smuggling-migrants-mexico-bor -

der-drugs ; Ginger Gibson, “Trump says

immigrants are ‘poisoning the blood

of our country.’ Biden campaign likens

comments to Hitler,” NBC News, December

17, 2023, https://www.nbcnews.com/

politics/2024-election/trump-says-im -

migrants-are-poisoning-blood-country-

biden-campaign-liken-rcna130141 .

89 “At Iowa rally, Trump doubles down on

comments about immigrants poisoning the

nation’s blood,” PBS, December 20, 2023,

https://www.pbs.org/newshour/politics/

at-iowa-rally-trump-doubles-down-on-

comments-about-immigrants-poisoning-

the-nations-blood .

90 “Quick Facts: Fentanyl Trafficking,” United

States Sentencing Commission, 2023,

https://www.ussc.gov/sites/default/files/

pdf/research-and-publications/quick-facts/

Fentanyl_FY23.pdf .

91 David J. Bier, “U.S. Citizens Were 89%

of Convicted Fentanyl Traffickers in

2022,” The CATO Institute, August 23,

2023, https://www.cato.org/blog/us-cit -

izens-were-89-convicted-fentanyl-traf -

fickers-2022 ; Natalie Kitroeff and Robert

Gebeloff, “The American Drug Mules

Smuggling Fentanyl Into the U.S.,” The New

York Times , September 28, 2024, https://

www.nytimes.com/2024/09/28/world/

americas/fentanyl-drug-smugglers-us.

html.

92 Ibid.93 Asawin Suebsaeng and Adam Rawnsley,

“Trump Asks Advisers for ‘Battle Plans’ to

‘Attack Mexico’ If Reelected,” Rolling Stone ,

March 29, 2023, https://www.rollingstone.

com/politics/politics-features/donald-

trump-mexico-military-cartels-war-on-

drugs-1234705804/ .

94 See, for example, Ken Cuccinelli, “It’s

Time to Wage War on Transnational Drug

Cartels,” Center for Renewing America,

October 11, 2022, https://americarenewing.

com/issues/its-time-to-wage-war-on-

transnational-drug-cartels/ ; Asawin

Suebsaeng, “Trump Is Planning to Send

Kill Teams to Mexico to Take Out Cartel

Leaders,” Rolling Stone , May 7, 2024,

https://www.rollingstone.com/politics/

politics-features/trump-mexico-kill-teams-

drug-cartels-1235016514/ ; Isaac Arnsdorf

and Mary Beth Sheridan, “Republican

hopefuls ramp up war talk over Mexican

border,” The Washington Post , September

12, 2023, https://www.washingtonpost.

com/politics/2023/09/12/mexico-bor -

der-war-fentanyl/ .

95 “Presidents should use full power of U.S.

military to go after cartels: Full Sen. J.D.

Vance,” NBC News, July 2, 2023, https://

www.nbcnews.com/meet-the-press/video/

presidents-should-use-full-power-of-u-s-

military-to-go-after-cartels-full-sen-j-d-

vance-186528837990 .

96 Edward Wong et al., “State Dept.

Draws Up List of Cartels to Be Labeled

Terrorist Groups,” The New York Times ,

February 12, 2025, https://www.

nytimes.com/2025/02/12/us/politics/

state-dept-terrorist-designation.html .

97 Vanda Felbab-Brown, “The New War on

Drugs,” Foreign Affairs , February 17, 2025,

https://www.foreignaffairs.com/canada/

new-war-drugs?check_logged_in=1 .

98 Vanda Felbab-Brown’s interview with U.S.

officials during the first Trump administra -

tion, spring 2020.

99 Vanda Felbab-Brown, “Prospects and

Possibilities for US-Mexico Security

Cooperation.”.

100 See, for example, Zeke Miller, Aamer

Madhani, and Tara Copp, “US forces strike

Houthi sites in Yemen as Biden says allied

action hasn’t yet stopped ship attacks,”

Associated Press, January 19, 2024,

https://apnews.com/article/biden-houth -

is-yemen-shipping-attacks-fc5c1ed -

40f4e370bed81670bfdda0899 .

101 Eric Halliday and Connor Veneski, “What

Happens If the Trump Administration

Designates Drug Cartels as Terrorist

Organizations?” Lawfare, April 8, 2020,

https://www.lawfaremedia.org/article/

what-happens-if-trump-administra -

tion-designates-drug-cartels-terrorist-or -

ganizations .

102 “Money sent home by Mexicans working

abroad rose by 7.6% in 2023, to reach a

record $63 billion,” The Associated Press,

February 1, 2024, https://apnews.com/

article/mexico-remittances-record-mon -

ey-migrants-275a49302e840fdaa8060d -

5cab9c7a24 .

103 Salvador Rivera, “Economist says mass

deportations will cost Mexico tens of

billions of dollars, a blow to its economy,”

The Border Report, December 29, 2024,

https://www.borderreport.com/news/econ -

omist-says-mass-deportations-will-cost-

mexico-tens-of-billions-of-dollars-a-blow-

to-its-economy/ .

104 Annie Correal, “Honduras Threatens to

Expel U.S. Military as Latin America Gears

Up for Trump Deportations,” The New

York Times , January 3, 2025, https://www.

nytimes.com/2025/01/03/world/americas/

honduras-trump-mass-deportations.html .

105 Vanda Felbab-Brown, “Addressing Mexico’s

Role in the U.S. Fentanyl Epidemic”; Maria

Abi-Habib and Simon Romero, “Labeling

Mexican Cartels ‘Terrorists’ Could Expose

U.S. Companies to Sanctions,” The New York Times , January 22, 2025, https://

www.nytimes.com/2025/01/22/world/

americas/mexico-cartel-terrorists-trade.

html.

106 Josh Boak, “Trump says Americans could

feel ‘some pain’ from his new tariffs”;

Costas Pitas, “Trump vows new Canada,

Mexico, China tariffs.”

107 Warwick J. McKibbin and Marcus Noland,

“US tariffs on Canada and Mexico would

hurt all three economies; retaliation would

worsen the damage,” Peterson Institute for

International Economics, February 4, 2025,

https://www.piie.com/blogs/realtime-eco -

nomics/2025/us-tariffs-canada-and-mexi -

co-would-hurt-all-three-economies .

108 Editorial, “Gobierno de Sheinbaum inició

el despliegue de los 10 mil efectivos de la

Guardia Nacional” [Sheinbaum’s govern -

ment began the deployment of 10,000

National Guard tropos], Proceso, February

4, 2025, https://www.proceso.com.mx/

nacional/2025/2/4/gobierno-de-shein -

baum-inicio-el-despliegue-de-los-10-mil-

efectivos-de-la-guardia-nacional-344985.

html; Octavio Martinz, “Guardia Nacional

abandona vigilancia de Cancún y Riviera

Maya para irse a la frontera con EU”

[National Guard abandons surveillance

of Cancun and Riviera Maya to go to the

border with the US], Proceso, February

4, 2025, https://www.proceso.com.mx/

nacional/2025/2/4/guardia-nacional-aban -

dona-vigilancia-de-cancun-riviera-maya-pa -

ra-irse-la-frontera-con-eu-344932.html .

109 Mary Beth Sheridan, “Mexico sent

10,000 troops to stop fentanyl. It remains

elusive.,” The Washington Post , March 1,

2025, https://www.washingtonpost.com/

world/2025/03/01/mexico-border-fentan -

yl-trump-trade/ ; Natalie Kitroeff and Paulina

Villegas, “Trump’s Threats and Mexico

Crackdown Hit Mexican Cartel,” The New

York Times , March 2, 2025, https://www.

nytimes.com/2025/03/02/world/americas/

mexico-cartel-fentanyl-trump-tariffs.html .

110 Drazen Jorgic, Laura Gottesdiener, and

Lizbeth Diaz, “Mexico sends major drug

capos to US as Trump tariff threat looms,”

Reuters, https://www.reuters.com/world/

americas/mexico-extradite-us-convict -

ed-drug-kingpin-caro-quintero-other-sus -

pected-cartel-2025-02-27/ .

111 Christine Murray, “Mexico makes largest

fentanyl bust as Donald Trump’s tariff

threat looms,” The Financial Times ,

December 4, 2024, https://www.ft.com/

content/e589d61b-eba2-483d-b88c-

718d9da3a8ab .

112 See Vanda Felbab-Brown, “The Wall:

The Real Costs of a Barrier between the

United States and Mexico,” The Brookings

Institution, August 2017, https://www.

brookings.edu/articles/the-wall-the-real-

costs-of-a-barrier-between-the-united-

states-and-mexico/ .

113 Vanda Felbab-Brown, “Mexico’s Out-of-

Control Criminal Market,” (Washington,

DC: The Brookings Institution, March 2019,

https://www.brookings.edu/wp-content/

uploads/2019/03/FP_20190322_mexico_

crime-2.pdf .

114 Salvador Corona, Pedro Villa y Caña,

“Sheinbaum va contra finanzas del crimen

con gabinete alerno” [Sheinbaum goes

against criminal finances with an alternate

cabinet], El Universal , October 8, 2024,

https://www.eluniversal.com.mx/nacion/

sheinbaum-va-contra-finanzas-del-cri -

men-con-gabinete-alterno/ ; José de

Córdoba, “Inside Mexico’s New Plan to

Take on Cartel Violence,” The Wall Street

Journal , October 7, 2024, https://www.wsj.

com/world/americas/inside-mexicos-new-

plan-to-take-on-cartel-violence-fcff2a54 .

115 “U.S.-Mexico Security Cooperation: From

the Mérida Initiative to the Bicentennial

Framework,” (Washington, DC:

Congressional Research Service, October

9, 2023), https://crsreports.congress.gov/

product/pdf/IF/IF10578/29 . 116 Ibid.

117 Emiliano Rodríguez Mega, James

Wagner, and Alan Yuhas, “Mexico Remakes

Its Entire Judicial System as States Back

Vast Overhaul,” The New York Times,

September 12, 2024, https://www.nytimes.

com/2024/09/12/world/americas/mexico-

courts-overhaul-states-approve.html .

118 Guillermo Trejo and Sandra Ley, Votes,

Drugs, and Violence: The Political Logic

of Criminal Wars in Mexico (Cambridge,

UK: Cambridge University Press, 2020);

Vanda Felbab-Brown and Diana Paz García,

“Mexico, López Obrador, and Sheinbaum’s

presidential victory,” The Brookings

Institution, June 10, 2024, https://www.

brookings.edu/articles/mexico-lopez-obra -

dor-and-sheinbaums-presidential-victory/ .

119 Ana Swanson, “Trump Hits Foreign Steel

and Aluminum With Tariffs, Restarting

an Old Fight,” The New York Times ,

February 10, 2025, https://www.nytimes.

com/2025/02/10/us/politics/trump-tariffs-

steel-aluminum.html .

120 María Verza, “Mexico to impose retaliatory

tariffs on US following China and Canada

as trade war heats up,” The Associated

Press, March 4, 2025, https://apnews.com/

article/trade-war-mexico-trump-9cefd -

ded035a0b35e700a7ba0bfc34b4 .

121 Vanda Felbab-Brown, “Mexico’s Out-of-

Control Criminal Market.”

122 Vjosa Isai, “Behind Closed Doors,

Trudeau Says Trump Threat to Take Over

Canada Is Real,” The New York Times ,

February 7, 2025, https://www.nytimes.

com/2025/02/07/world/canada/trump-can -

ada-trudeau.html .

123 “Opioid- and Stimulant-related Harms

in Canada,” Government of Canada,

September 2024, https://health-infobase.

canada.ca/substance-related-harms/

opioids-stimulants/ .

124 Darren Major, “Will Canada listing drug

cartels as terrorists change anything?”

CBC News, February 8, 2025, https://www.

cbc.ca/news/politics/canada-drug-cartels-

terrorist-list-trump-tariffs-1.7453894 .

125 David Ovalle and Nick Miroff, “Fentanyl

super labs in Canada pose new threat for

U.S. opioid epidemic,” The Washington

Post , December 24, 2023, https://www.

washingtonpost.com/health/2023/12/24/

fentanyl-labs-canada-threat-to-us/ .

126 Ibid.

127 “Drug seizure statistics,” U.S. Customs and

Border Protection, retrieved on February

12, 2025, from https://www.cbp.gov/news -

room/stats/drug-seizure-statistics .

128 Associated Press, “Canada’s new fentanyl

czar says goal is to totally stop the drug

from entering the US,” KSDK, February 12,

2025, https://www.ksdk.com/article/news/

nation-world/canada-new-fentanyl-czar-

appointed-details-goals/507-ed46b1d4-

35ca-4c43-9543-42e8a220148d?utm_

campaign=snd-autopilot .

129 Ibid.

130 Benjamin Lopez Steven, “Canada’s ‘fentanyl

czar’ will be appointed before Trump’s tariff

pause ends: public safety minister,” CBC,

February 6, 2025, https://www.cbc.ca/

news/politics/fentanyl-czar-border-secu -

rity-1.7452829 .

131 Nadine Yousif and James FitzGerald,

“Canada hits US with retaliatory tariffs

after warning of ‘existential threat,’” BBC,

March 3, 2025, https://www.bbc.com/

news/articles/c89ye749nxvo .

132 Josh Boak, “Trump says Americans could

feel ‘some pain’ from his new tariffs.”

133 John Ruwitch, “Chinese countertariffs to

kick in.”

134 Brooke Singman, “Trump pledges to battle

drug cartels.”135 Ibid.

136 Kelly Garrity, “Vance, Brown call for action

against China over fentanyl crisis,” Politico,

July 2, 2023, https://www.politico.com/

news/2023/07/02/vance-brown-fentanyl-

china-00104530 .

137 Andrés Martínez-Fernández and Andrew

J. Harding, “Holding China and Mexico

Accountable for America’s Fentanyl Crisis,”

(Washington, DC: The Heritage Foundation,

September 9, 2024), https://www.heritage.

org/sites/default/files/2024-09/BG3851.

pdf.

138 “Senator Vance Questions Former DEA

Agent on Rising Threat of Nitazenes,”

Office of Former Sen. JD Vance, January

11, 2024, https://www.legistorm.

com/stormfeed/view_rss/2332163/

member/3556/title/senator-vance-ques -

tions-former-dea-agent-on-rising-threat-

of-nitazenes.html .

139 See, for example, “Congresswoman

Lauren Boebert Reintroduces Legislation

to Protect our Children by Classifying

Fentanyl as a Weapon of Mass

Destruction,” Representative Lauren

Boebert, February 1, 2024, https://boebert.

house.gov/FentanylWMDAct#:~:text=B

ackground%3A-,The%20Fentanyl%20

is%20a%20Weapon%20of%20Mass%20

Destruction%20(WMD)%20Act,a%20

weapon%20of%20mass%20destruction .

140 Vanda Felbab-Brown’s interviews with

Chinese and U.S. law enforcement officials,

spring and fall 2024.

141 Nate Raymond, “Trump pardons Silk Road

founder Ross Ulbricht for online drug

scheme,” Reuters, January 22, 2025,

https://www.reuters.com/world/us/trump-

pardons-silk-road-founder-ulbricht-online-

drug-scheme-2025-01-22/ .

142 Vanda Felbab-Brown, “US-China relations

and fentanyl and precursor cooperation in

2024,” The Brookings Institution, February

29, 2024, https://www.brookings.edu/

articles/us-china-relations-and-fentan -

yl-and-precursor-cooperation-in-2024/ .

143 Vanda Felbab-Brown’s interviews with U.S.

law enforcement officials, fall 2024.

144 See, for example, “White House Drug

Policy Director Statement on PRC Fentanyl

Precursor Scheduling Actions,” Office of

National Drug Control Policy, August 6,

2024, https://bidenwhitehouse.archives.

gov/ondcp/briefing-room/2024/08/06/

white-house-drug-policy-director-state -

ment-on-prc-fentanyl-precursor-schedul -

ing-actions/ ; Brian Mann, “Critics wary as

China promises tighter fentanyl controls,”

NPR, August 30, 2024, https://www.npr.

org/2024/08/29/nx-s1-5089978/fentan -

yl-china-precursors .

145 Vanda Felbab-Brown’s interviews with U.S.

government officials, spring 2024.

146 Vanda Felbab-Brown’s interviews with

Chinese officials, fall 2024.

147 Steven Dudley et al., The Flow of Precursor

Chemicals for Synthetic Drug Production

in Mexico, InSight Crime, May 2023,

https://insightcrime.org/wp-content/

uploads/2023/05/The-Flow-of-Precursor-

Chemicals-for-Synthetic-Drug-Production-

in-Mexico-InSight-Crime-March-2023-3.

pdf.

148 See, for example, Maurice Tamman, Laura

Gottesdiener, and Stephen Eisenhammer,

“We bought everything needed to make $3

million worth of fentanyl.”

149 Natalie Kitroeff and Paulina Villegas,

“Mexican Cartels Lure Chemistry Students

to Make Fentanyl.”

150 Vanda Felbab-Brown’s interviews with U.S.

government and law enforcement officials,

summer and fall 2024.151 “Supplemental Advisory on the

Procurement of Precursor Chemicals and

Manufacturing Equipment Used for the

Synthesis of Illicit Fentanyl and Other

Synthetic Opioids,” U.S. Department

of Treasury, June 20, 2024, https://

www.fincen.gov/sites/default/files/advi -

sory/2024-06-20/FinCEN-Supplemental-

Advisory-on-Fentanyl-508C.pdf .

152 See, for example, “Federal Indictment

Alleges Alliance Between Sinaloa

Cartel and Money Launderers Linked

to Chinese Underground Banking,” U.S.

Department of Justice, June 18, 2024,

https://www.justice.gov/archives/opa/pr/

federal-indictment-alleges-alliance-be -

tween-sinaloa-cartel-and-money-launder -

ers-linked .

153 Vanda Felbab-Brown’s interviews with U.S.

law enforcement and government officials,

summer and fall 2024.

154 Vanda Felbab-Brown’s interviews with

Chinese government officials, November

2024.

155 “Presidential Determination on Major Drug

Transit or Major Illicit Drug Producing

Countries (Majors List),” U.S. Department

of State, September 2024, https://

www.state.gov/presidential-determina -

tion-on-major-drug-transit-or-major-illic -

it-drug-producing-countries-majors-list/ .

156 See, for example, Andrés Martínez-

Fernández and Andrew J. Harding,

“Holding China and Mexico Accountable

for America’s Fentanyl Crisis”; “China’s Role

in the Fentanyl Crisis,” (Washington, DC:

The Select Committee on the Strategic

Competition between the United States

the Chinese Communist Party, April 2024),

https://selectcommitteeontheccp.house.

gov/sites/evo-subsites/selectcommittee -

ontheccp.house.gov/files/evo-media-docu -

ment/The%20CCP%27s%20Role%20in%20

the%20Fentanyl%20Crisis%204.16.24%20

%281%29.pdf ; and David S. Luckey’s

comments in “China and Transnational

Crime: Fentanyl and Beyond” (webinar,

Initiative for U.S.-China Dialogue on Global

Issues, Georgetown University, November

7, 2024), https://uschinadialogue.george -

town.edu/events/china-and-transnation -

al-crime-fentanyl-and-beyond .

157 Vanda Felbab-Brown, “China and Synthetic

Drugs Control.”

158 Vanda Felbab-Brown’s interviews with

Chinese government officials, November

2024.

159 Ibid.; Marius Zaharia, “Why Trump tariffs

pose a bigger threat to China’s economy

this time,” Reuters, November 6, 2024,

https://www.reuters.com/world/china/

why-chinas-economy-is-more-vulnera -

ble-trump-tariffs-this-time-2024-11-06/ .

160 Annie Correal, “What to Know About

Trump’s Military Deportation Flights,” The

New York Times , January 30, 2025, https://

www.nytimes.com/2025/01/31/world/amer -

icas/trump-military-deportation-flights.

html; Carol Rosenberg, “What We Know

About the Secretive Migrant Mission at

Guantánamo Bay,” The New York Times ,

February 19, 2025, https://www.nytimes.

com/2025/02/19/us/politics/migrant-mis -

sion-guantanamo-bay.html ; and Julie

Turkewitz et al., “Migrants, Deported to

Panama Under Trump Plan, Detained in

Remote Jungle Camp,” The New York

Times , February 19, 2025, https://www.

nytimes.com/2025/02/19/world/americas/

us-migrants-panama-jungle-camp.html .

161 Josh Meyer, “Thousands of DHS agents shift

to deportations instead of drugs, weapons

and human trafficking,” USA Today, February

14, 2025, https://www.usatoday.com/story/

news/politics/2025/02/14/dhs-agents-de -

portation-not-trafficking/78641666007/ ;

Glenn Thrush, “Justice Dept. to Investigate

Local Officials Who Obstruct Immigration

Enforcement,” The New York Times ,

January 22, 2025, https://www.nytimes.

com/2025/01/22/us/politics/justice-depart -

ment-immigration-enforcement.html . 162 “Ending America’s Opioid Crisis, October

2017,” The White House, https://trump -

whitehouse.archives.gov/opioids/ ; Julie

Hirschfeld David, “Trump Declares

Opioid Crisis a ‘Health Emergency’ but

Requests No Funds,” The New York Times ,

October 26, 2017, https://www.nytimes.

com/2017/10/26/us/politics/trump-opioid-

crisis.html .

163 “SUPPORT for Patients and Communities

Act.”

164 “Former President Trump Calls for Death

Penalty for Drug Dealers,” C-SPAN,

November 15, 2022, https://www.c-span.

org/video/?c5041276/president-trump-

calls-death-penalty-drug-dealers .

165 Brooke Singman, “Trump pledges to battle

drug cartels.”

166 “Former President Trump Calls for Death

Penalty,” C-SPAN.

167 Ibid.

168 “The Death Penalty for Drug Offenses:

Global Overview 2023,” (London: Harm

Reduction International, 2023), https://hri.

global/flagship-research/death-penalty/

the-death-penalty-for-drug-offenc -

es-global-overview-2023/#:~:text=At%20

the%20end%20of%202023,Control%20

of%20Narcotics%20Substances%20Act ;

Vanda Felbab-Brown, “The Middle East Is

Awash in Drugs.”

169 Roland Neil and Beau Kilmer, “Criminal

Legal Interventions During the Overdose

Crisis.”

170 Jason M. Blazakis, “The Case against

Designating Cartels as Terrorists,”

The Wall Street Journal , February 19,

2025, https://www.wsj.com/opinion/

the-case-against-designating-car -

tels-as-terrorists-90c6c44f .

171 Brooke Singman, “Trump pledges to battle

drug cartels.”

172 See, for example, Boris Miranda, “‘Son

más duros que cualquier persona que

hayas conocido’: la expansión de la Mara

Salvatrucha en Estados Unidos que

preocupa a Donald Trump” [“They are

tougher than anyone you’ve ever met”:

The Mara Salvatrucha gang’s expansion in

the United States worries Donald Trump],

BBC Mundo, March 10, 2017, https://

www.bbc.com/mundo/noticias-interna -

cional-39201690 ; Gerardo Lissardy, “‘No son

personas, son animales’: cómo el discurso

de Trump contra la Mara Salvatrucha

podría beneficiar a la pandilla” [“They are

not people, they are animals”: How Trump’s

speech against Mara Salvatrucha could

benefit the gang], BBC Mundo, May 23,

2018, https://www.bbc.com/mundo/noti -

cias-internacional-44233414 .

173 Gene Hamilton, “The Department of

Justice,” in Paul Dans and Steven

Groves, eds. Mandate for Leadership:

The Conservative Promise (Washington,

DC: The Heritage Foundation, 2023),

https://static.project2025.org/2025_

MandateForLeadership_FULL.pdf .

174 “Trump Disavows Project 2025,” C-SPAN,

July 20, 2024, https://www.c-span.org/

video/?c5124900/donald-trump-disavows-

project-2025 .

175 See, for example, Sen. John Kennedy,

“Woke cities and states reverse course

and crack down on illegal drugs. Here’s

why,” May 14, 2024, https://www.kennedy.

senate.gov/public/2024/5/woke-cities-

and-states-reverse-course-and-crack-

down-on-illegal-drugs-here-s-why .

176 For further information on these mech -

anisms, see Vanda Felbab-Brown and

Michael Sinclair, “How to Increase

Vaccination and Mask-Wearing to Defeat

COVID-19,” The Hill, January 5, 2021,

https://thehill.com/opinion/health -

care/532633-how-to-increase-vaccina -

tion-and-mask-wearing-to-defeat-covid-

19/?rnd=1609816163.177 Regina LaBelle, “Looking Ahead: Drug

Policy in the Next Trump Administration,”

Georgetown University Law School,

November 7, 2024, https://oneill.

law.georgetown.edu/drug-poli -

cy-in-the-trump-administration/ .

178 Nicole Gastala, Harold Pollack, et

al., “Expanding Access to Addiction

Treatment”; Regina LaBelle and David

Holtgrave, “Harm Reduction and Its Role in

Improving Health Outcomes.”

179 “U.S. cities that followed ‘Portugal model’

have seen drug overdoses rise, says Sen.

J.D. Vance,” NBC News, July 2, 2023,

YouTube video, 1:22, https://www.youtube.

com/watch?v=WPA0K5_7w5s .

180 Ibid.

181 Fernanda Figueroa, Ayanna Alexander,

and Corey Williams, “Trump order

ending federal DEI programs leaves

agencies and stakeholders on uncer -

tain ground,” The Associated Press,

January 23, 2025, https://apnews.com/

article/trump-dei-executive-order-di -

versity-inclusion-f67ea86032986084d -

d71c5aa0c6b8d1d

182 Cameron Santoro, “The Uncertain Road

Ahead for Health Care After DEI Rollbacks,”

American Journal of Managed Care ,

February 7, 2025, https://www.ajmc.com/

view/the-uncertain-road-ahead-for-

health-care-after-dei-rollbacks .

183 Brooke Singman, “Trump pledges to battle

drug cartels.”

184 Jan Hoffman, “Kennedy’s Plan for the

Drug Crisis: A Network of ‘Healing Farms,’”

The New York Times , https://www.

nytimes.com/2025/01/18/health/rfk-ad -

diction-farms.html ; Brian Mann, “RFK Jr.

says he’ll fix the overdose crisis. Critics

say his plan is risky,” NPR, January 29,

2025, https://www.npr.org/2025/01/29/

nx-s1-5276898/rfk-drugs-addiction-over -

dose-hhs-confirmation-trump .

185 Ibid.

186 Alissa Zhu, Nick Thieme, and Jessica

Gallagher, “Almost 6,000 Dead in 6

Years: How Baltimore Became the U.S.

Overdose Capital,” The New York Times ,

May 23, 2024, https://www.nytimes.

com/2024/05/23/us/baltimore-opioid-epi -

demic-od-deaths.html ; Alissa Zhu, Jessica

Gallagher, and Meredith Cohn, “They

Entered Treatment. Drugs, Overdoses and

Deaths Followed,” The New York Times ,

December 20, 2024, https://www.nytimes.

com/2024/12/20/us/baltimore-overdos -

es-drug-treatment.html .

187 Ibid.188 Russ Vought, “Executive Office of

the President of the United States,

Office of National Drug Control Policy,”

in Paul Dans and Steven Groves,

eds. Mandate for Leadership: The

Conservative Promise (Washington,

DC: The Heritage Foundation, 2023),

https://static.project2025.org/2025_

MandateForLeadership_FULL.pdf .

189 “The Killing Drugs: Synthetic Opioids

around the World,” podcast, The Brookings

Institution, 2024, https://www.brookings.

edu/tags/the-killing-drugs/ .

About the author

Vanda Felbab-Brown is a senior fellow in the Strobe Talbott Center for Security, Strategy, and

Technology in the Foreign Policy program at Brookings, and is the director of the Initiative on Nonstate

Armed Actors.

Acknowledgments

My immense thanks go to Diana Paz García, whose multifaceted and indispensable collaboration,

including crucial research support, contributed enormously to this chapter and the entire project. I

would also like to thank Ryan Beane for further invaluable research assistance. I am grateful to the

anonymous reviewers for their helpful suggestions, to Jeffrey Castle and Adam Lammon for their

superb editing of the paper, and to Rachel Slattery for the terrific layout.

Disclaimer

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