An unprecedented legal complaint has been submitted to the Warsaw prosecutor regarding the role of Polish state-owned company Nitrochem in supplying TNT for Israel’s key tools of genocide. The step could not only interrupt a hugely strategic component in the supply chain for genocide but also help end Polish state complicity in crimes against humanity.

Yesterday, three international organizations, the Hind Rajab Foundation, the International Federation for Human Rights  and the European Legal Support Centre, 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, 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.

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, Shadow World Investigations and the Movement Research Unit  — drawing on Open-Source Intelligence.

According to the report, Nitro-Chem is the largest TNT producer supplying NATO and the EU, and a key supplier to the United States military. Polish officials have publicly stated that roughly 90% of the TNT imported by the U.S. comes from Poland. 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.

The report documents Nitro-Chem’s central role in this supply chain. In a 2018 presentation cited in the report, General Dynamics, the US 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 US $310 million.

The report estimates that, between October 2023 and July 2024, the US 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 US, 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 US to Israel and used against Palestinians in Gaza.

A coalition of legal organizations 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 US since at least 2004.

The coalition further submits that the US 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 US, and the US and Israel, it is highly likely that Polish TNT was incorporated into the explosive ordnance manufactured by the US 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 US 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 US-made bombs and artillery shells against the population of Gaza has been a matter of public record. Moreover, Nitro-Chem’s contracts with the US 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 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.

“A watershed moment”

Activist Ewa Jasiewicz, who took part in last autumn’s Global Sumud Flotilla to Gaza, told Labour Hub: “This strategic legal action marks a watershed moment and challenge to states for their constant failure to comply with their obligations under international law, laws which in large part were created in response to the genocide and crimes against humanity committed in living memory in Poland. 

“We can still stop Israel’s genocide – which we know will not stop with Gaza, where around two million people are still alive, still fighting for survival and stay rooted in their land. It will continue throughout the West Bank and Jerusalem and historical Palestine and wider Levant region – all made possible with international state and corporate complicity. But it’s all defeatable by the power of our unified, collective, tactic-diverse social movements all over the world in solidarity with liberation for Palestine and all peoples fighting colonialism, racism, fascism and ecocide in all its forms.”

Read the report The Missing Ingredient: Polish TNT

Image: c/o Bryn Griffiths