The Starting Point of Safeguards Natural uranium is considered to be source material under the IAEA Statute and thus a type of nuclear material as defined in IAEA document INFCIRC/153, which defines the starting point for full safeguards (i.e. the application of the full set of accountancy and control provisions on nuclear material inventory). Paragraph 34(c) is commonly referred to in the safeguards community as ‘the starting point of safeguards.’ It states:

When any nuclear material of a composition and purity suitable for fuel fabrication or for being isotopically enriched leaves the plant or the process stage in which it has been produced, or when such nuclear material, or any other nuclear material produced at a later stage in the nuclear fuel cycle, is imported into the State, the nuclear material shall become subject to the other safeguards procedures specified in the Agreement.

Safeguards1 therefore start when nuclear material ‘leaves the plant or process stage’, and has historically been interpreted as the output of conversion plants (i.e. Uranium Hexafluoride or UF6). INFCIRC/153 does not apply to material in mining or ore processing/milling activities.

The Starting Point of Safeguards In 2003 the IAEA reinterpreted the starting point with the introduction of ‘Policy Paper 18’ under which safeguards were applied to the production of purified uranyl nitrate or the first practical point earlier. This captured material in process at conversion plants and therefore UOC remains a ‘pre-34c’ material and not subject to the full scope of IAEA accountancy and control provisions. UOC, however, is used to feed subsequent stages of the nuclear supply chain and therefore the IAEA still requires information on exports and imports.

Import/Export Reporting Given that natural uranium can be used to feed subsequent stages of the fuel cycle, INFCIRC/153 (Paragraphs 34a and 34b) requires states to report the import and export of any material containing uranium or thorium, even trace quantities, if such material is exported for nuclear purposes (i.e. to be used in a nuclear reactor) to a non-nuclear weapon state. Although the rule does not apply to nuclear weapons states, they do voluntarily provide this information to the IAEA.

Reporting on Uranium Deposits The 1997 Additional Protocol requires annual reporting on a states’ uranium and thorium holdings (location, number of operational mines, purity, and production capacity for the year prior and potential for the year ahead). Most uranium suppliers have concluded a Protocol Additional to their existing safeguards agreements. As of 5 November 2014, 124 states (including Euratom) had the Additional Protocol in force. The IAEA maintains an updated status report, which can be found here:

Although IAEA safeguards do not explicitly call for export controls to be developed within a state, the reporting of imports and exports requires states to apply prudent controls and evaluate the risk that uranium will be extracted and/or traded for nuclear purposes. If the risk is great enough, the IAEA requires that states apply appropriate controls. The challenge for states however is that ‘prudent’ or ‘appropriate’ controls are not prescribed by the IAEA and therefore interpretation is left to states. That said, export controls are required by the UN Security Council Resolution 1540 of 2004.

Physical protection of nuclear material The key convention covering physical protection, the Convention on the Physical Protection of Nuclear Materials (CPPNM) also states “prudent management practice” is required to secure nuclear material, but it doesn’t elaborate any further on exactly what such a practice entails. The IAEA has drafted a “tech doc” on “Uranium Security for the Uranium Industry” which takes a graded approach to security practices. It should be published in 2015 or 2016.

CPPNM AmendmentThe CPPNM was amended in 2005 to extend its provisions to domestic use, storage and transport. It also provided for expanded cooperation between and among states regarding rapid measures to locate and recover stolen or smuggled nuclear material, mitigate any radiological consequences of sabotage and prevent and combat related offences. The amendment will enter into force when two-thirds of States Parties have ratified it.

As of December 1, 2014, 55% (83 out of 150 states parties) have ratified the amendment. Major uranium producers such as Australia, Canada and Kazakhstan have ratified the amendment, and apply the CPPNM’s provisions domestically. The same goes for China, France, Russia and the United Kingdom. Others, such as Brazil, Iran, Malawi, Tanzania and the United States have yet to ratify.


Safeguards are activities by which the IAEA can verify that a state is living up to its international commitments not to use nuclear programmes for nuclear weapons purposes.