BREAKING: Criminal Complaint Filed in Poland Against Largest Producer of TNT in NATO for its Role in the Gaza Genocide

On 26 June 2026, three international organizations, 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.

In parallel, three leading Palestinian human rights organizations: Al-Haq, Al-Mezan, the Palestinian Centre for Human Rights (PCHR), in addition to individual survivors of the genocide, will become parties to the proceedings against Nitro-Chem. Their submissions will detail the extent and scale of the destruction caused in Gaza.

A woman sits near an unexploded munition in a displaced persons camp for Palestinians, Gaza City, April 19, 2025. Photo: © Yousef Zaanoun / Activestills

The Supply Chain

The complaint is largely based on the report "The Missing Ingredient: Polish TNT" published by three research organizations — 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 United States (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 a new plant expected to become operational in 2028.

Thus, U.S. arms manufacturers have relied on imports for several years. The report further 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 meters. 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 these types of munitions across Gaza, including in densely populated areas.

Israeli military bomb Al-Yazi residential buildings and commercial shops near Qashqar Mosque, in Gaza old city, May 30, 2025. Photo: © Yousef Zaanoun / Activestills

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 these 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 and with a new deal in April 2024, followed by another contract signed in April 2025 worth approximately USD 310 million.

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-ton 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.

A coalition of legal organizations — HRF, FIDH and ELSC — argues that this supply chain may engage criminal liability.

In the coalition’s 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 the Mk 80 series and BLU-109 bombs) and artillery shells manufactured in the U.S. since at least 2004.

The coalition further submits 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 utilized these specific munitions to conduct systematic attacks against densely populated civilian areas — a campaign widely recognized 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.

Palestinian families return to what remains of their homes in the Sheikh Radwan area of the devastated Gaza City, October 11, 2025. Photo: © Yousef Zaanoun / Activestills

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 (ICJ) recognized a plausible risk of genocide in January 2024.

The supply of TNT continued after the International Criminal Court (ICC) issued arrest warrants against Israeli leaders for international crimes in Gaza in November 2024. Supplies also continued despite successive UN findings—including the UN Commission of Inquiry findings, released in September 2025, that Israeli authorities and Israeli security forces have committed and are continuing to commit genocide against the Palestinians in the Gaza Strip.

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 Polish law, both of which criminalize aiding international crimes.

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Link to the report: “The Missing Ingredient: Polish TNT” 

Spokespersons contact details:

• The Hind Rajab Foundation (HRF): pr@hindrajabfoundation.be
• Al-Haq: media@alhaq.org
• International Federation for Human Rights (FIDH): Raphaël Lopoukhine: rlopoukhine@fidh.org | +33 6 72 28 42 94