On 26 June 2026, three international organisations, the Hind Rajab Foundation (HRF), the International Federation for Human Rights (FIDH) and the European Legal Support Center (ELSC), filed a criminal complaint against representatives of Nitro-Chem, a state-owned company based in Poland and the largest producer of TNT in NATO, for alleged involvement in international crimes against Palestinians in Gaza.
Adjacently, three leading Palestinian human rights organisations: Al-Haq, Al-Mezan, the Palestinian Centre for Human Rights (PCHR), along with individual survivors of the genocide, are expected to file their own complaints against Nitro-Chem and become parties to the proceedings. Their submissions will detail the extent and scale of the destruction caused in Gaza.
The Supply Chain
The complaint is largely based on the report “The Missing Ingredient: Polish TNT” published by three research organisations — the Palestinian Youth Movement (PYM), Shadow World Investigations (SWI) and the Movement Research Unit (MRU) — drawing on Open-Source Intelligence (OSINT).
According to the report, Nitro-Chem is the largest TNT producer supplying NATO and the EU, and a key supplier to the U.S. military. Polish officials have publicly stated that roughly 90% of the TNT imported by the U.S. comes from Poland. This dependence exists because the U.S. stopped producing TNT domestically in 1986 and only decided to resume production in late 2024, with the new plant expected to become operational in 2028.
For years, U.S. arms manufacturers therefore relied on imports. The report alleges that Polish TNT has become an essential component in the production of large aerial bombs, particularly the Mk 80 series and BLU-109, as well as 155mm artillery shells.
These munitions are high-explosive, wide-area-effect weapons with a lethal radius that can extend across hundreds of metres. The artillery projectiles are also unguided. Their use in densely populated civilian areas breaches fundamental principles of international humanitarian law, on distinction, proportionality and precaution in attacks. Yet Israel has reportedly employed tens of thousands of both types of munitions across Gaza, including in densely populated areas.
The report documents Nitro-Chem’s central role in this supply chain. In a 2018 presentation cited in the report, General Dynamics, the U.S company producing the
munitions, described Nitro-Chem as “the only qualified TNT source for U.S. Bomb Programs.” The original 2016 contracts have been renewed and expanded repeatedly, even after October 2023, with a new deal in April 2024, followed by another contract worth around USD 310 million, signed in April 2025.
The report estimates that, between October 2023 and July 2024, the U.S. transferred to Israel at least 14,000 Mk 84 bombs, 6,500 Mk 82 bombs and 1,000 BLU-109 bunker-busters. These figures are likely an undercount, given that some 30,000 one-tonne bombs were dropped on Gaza between October 2023 and August 2024. Separately, the report documents that Nitro-Chem sold explosives, including TNT and RDX, directly to Israeli arms manufacturers such as IMI, Elbit and Rafael.
The report’s findings have reshaped the demands and strategy of the anti-genocide movement in Poland. Since its publication, stopping the TNT supply chain and ending Polish complicity in the ongoing genocide against Palestinians in Gaza and in other international crimes have become key demands of the local Embargo Now campaign (Embargo Teraz!).
The Complaint
Debates have since ensued in Poland over whether Nitro-Chem can be held accountable for selling TNT to the U.S., where it is mostly used to manufacture wide-area-effect munitions, including the Mk 80 series and 155mm artillery shells, which are likely transferred from the U.S. to Israel and used against Palestinians in Gaza.
The coalition of legal organisations — HRF, FIDH and ELSC — argues that this supply chain may engage criminal liability.
In their opinion, the evidence contained in the report and complemented by open-source investigations establishes that the TNT produced by Nitro-Chem served as an essential component for the production of aerial bombs (especially Mk 80 series and BLU-109 bombs), and artillery shells manufactured in the U.S. since at least 2004. They further submit that the U.S. subsequently transferred these specific types of munitions to Israel for use in its military operations, particularly during its genocide against the Palestinians. Additionally, records confirm that Nitro-Chem exported TNT and other explosives directly to Israel.
Given the long-term and continuous supply lines between Nitro-Chem and the U.S., and the U.S. and Israel, it is highly likely that Polish TNT was incorporated into the explosive ordnance manufactured by the U.S. and deployed by Israeli forces during the bombardment of Gaza. Evidence confirms that Israel utilised these specific munitions to conduct systematic attacks against densely populated civilian areas — a campaign
widely recognised by international bodies as constituting genocide, war crimes, and crimes against humanity — such that the continued provision of these critical raw materials by Nitro-Chem, whether via the U.S. channel or through direct sales, may amount to aiding the perpetration of grave international crimes.
Polish criminal law punishes genocide, war crimes and crimes against humanity (Articles 118, 118a and 122–126 of the Criminal Code), as well as anyone who aids such crimes.
The submission stipulates that a professional explosives manufacturer cannot credibly claim ignorance of these risks, considering that Israel’s use of U.S.-made bombs and artillery shells against the population of Gaza has been a matter of public record.
Moreover, Nitro-Chem’s contracts with the U.S. arms industry were renewed and expanded even after the International Court of Justice recognised a plausible risk of genocide in January 2024. The supply of TNT continued after the International Criminal Court issued arrest warrants against Israeli leaders for international crimes in Gaza in November 2024. Supplies continued despite successive UN findings—including the UN Commission of Inquiry finding that Israeli authorities and Israeli security forces have committed and are continuing to commit genocide against the Palestinians in the Gaza Strip in September 2025.
The complaint argues that continuing to supply the material while foreseeing and accepting these risks may constitute aiding the commission of international crimes. The notifying parties call for those acting on behalf of Nitro-Chem to be investigated.
The TNT Loophole
It is worth noting that pure TNT was removed from any licensing regime under both EU and Polish regulations in 2021. This occurred despite the absence of other major TNT producers in the EU, and despite the fact that a significant portion of the TNT manufactured in Poland is exported for military use without adequate end-use verification. However, this legal loophole does not absolve arms manufacturers of their general duties, nor does it exempt them from obligations under international humanitarian law and the Polish law, both of which criminalize aiding international crimes
Link to the report
“The Missing Ingredient: Polish TNT”: https://pchrgaza.org/wp-content/uploads/2026/06/Missing-Ingredient-Polish-TNT.pdf
