The point at which nuclear material becomes subject to comprehensive safeguards agreements with the International Atomic Energy Agency (IAEA) is commonly known as the “starting point of safeguards.” Paragraphs falling under this heading have remained unchanged since the publication of the model Comprehensive Safeguards Agreement (CSA) in 1972, although their interpretation and the measures applied to material both at and before the starting point, have evolved.

This has led to the capture by safeguards of more materials upstream in the nuclear fuel cycle that otherwise had fallen outside of international control, creating new obligations for states and industry, particularly for states with conversion facilities and producers of uranium ore concentrates (UOC). It has also led to more verification responsibilities for the IAEA.

This report is the product of two years of research studying the impact of evolving safeguards obligations on states, facility operators, and the IAEA at the front end of the nuclear fuel cycle.