What is being proposed
Palau's notification to the United Nations requests that the WHO Expert Committee on Drug Dependence (ECDD) conduct a scientific review of nicotine and assess whether it meets the criteria for scheduling under the 1971 Convention on Psychotropic Substances.
What scheduling means
International drug control exists to regulate psychoactive substances with significant dependence potential and threat to public health. Scheduling under the 1971 Convention gives countries an internationally recognised legal basis to regulate the manufacture, trade, and distribution of a substance, bringing it within the scope of international monitoring and supply chain oversight.
For governments, scheduling provides tools for additional oversight: licensing requirements at the point of manufacture, the ability to track trade flows across borders, and the means to act against producers and distributors operating outside regulated channels. It addresses the molecule wherever it appears, in whatever product format.
The 1971 Convention establishes four schedules, ranging from strict controls with limited permitted uses to lighter oversight for substances with recognised therapeutic applications. Which schedule applies — if any — is decided by a two-thirds majority vote of the UN Commission on Narcotic Drugs.
What scheduling means for nicotine replacement therapies
The 1971 Convention includes a mechanism to protect medicines with proven medical use and low abuse potential from the full scope of scheduling controls. WHO-recommended nicotine replacement therapies (NRTs) — patches, gums, lozenges, inhalers — could qualify under this mechanism, though the scope of any exemption is ultimately a decision for member states.
The same mechanism has been used to preserve medical access when other controlled substances with legitimate therapeutic uses have been brought under international control.
What happens after this notification?
The WHO Expert Committee on Drug Dependence will conduct an independent scientific review of nicotine, drawing on the supporting dossier submitted with Palau's notification, Member State questionnaire responses, and any additional evidence gathered during the review. The Committee will advise the WHO Director-General, who will transmit a scheduling recommendation to the United Nations Commission on Narcotic Drugs (CND). The CND, made up of 53 member states on a rotating basis, votes by two-thirds majority. A CND vote is anticipated for March 2028. During this process, the WHO Secretariat will invite all Member States to submit information and views through a standard questionnaire, providing a formal channel for governments to contribute to the review.