Who gains from saving nature
Ledger 1 : 33 — For each dollar financing nature-based solutions in 2023, about $33 financed activities harmful to nature. (UNEP)
Cases / Chemical pollution · Iran · 2017–2025

Iran's Clean Air Law and urban air pollution in Tehran and Ahvaz

Nature's voice · report
My air in Ahvaz averaged 42 micrograms of PM2.5 per cubic metre in the Iranian year 1403 and exceeded the WHO 24-hour guideline of 15 on 362 days, according to the Health Ministry.
Did nature suffer? Yes. Harm is on record. Disputed
Recorded
  • My air in Tehran averaged 32.9 micrograms of PM2.5 per cubic metre in 1403 and exceeded the guideline on 350 days, according to the Health Ministry. Zoomit
  • Tehran had 114 polluted days in 1400 and 170 in 1401, according to the Tehran judiciary. Mehr News Agency
  • The Article 90 Commission recorded unhealthy-for-sensitive-groups days in Tehran rising from 89 in 1399 to 115 in 1401. Mizan (Judiciary news agency)
People
  • About 58,975 people died.
    Attributed to PM2.5, Iranian year 1403 (March 2024 to March 2025), Health Ministry; about 161 a day.
  • About 20,837 people died.
    Iranian year 1400, studied cities, Article 90 Commission.
What the record lacks: 1 none on record · 3 not disclosed · 5 disputed · 1 unclear See the gaps
Accounts of the harm differ
Number of deaths attributable to air pollution
  • Government and regulators Article 90 Commission (27 June 2023): About 20,837 attributable deaths in 1400 in the studied cities. Mizan (Judiciary news agency)
  • Government and regulators Health Ministry (10 November 2025): About 58,975 deaths among people over 30 attributed to PM2.5 in 1403. Zoomit
Number of polluted days in Tehran in 1401
  • Government and regulators Article 90 Commission: 115 unhealthy-for-sensitive-groups days in 1401, up from 89 in 1399. Mizan (Judiciary news agency)
  • Courts Tehran Province Judiciary: 114 polluted days in 1400 and 170 in 1401. Mehr News Agency

A parliamentary commission found 22 of the 2017 Clean Air Law's 57 articles weakly implemented in 2023. The Health Ministry attributed 58,975 deaths among people over 30 to PM2.5 in the Iranian year 1403 and put the economic loss at about US$17.2 billion; the head of the Tehran Province Judiciary said five former managers were convicted of dereliction of duty under the law.

58,975Deaths attributed to PM2.5, Iranian year 1403 (March 2024 to March 2025), Health Ministry
People over 30, about 161 a day, with an economic loss of about US$17.2 billion (US$47 million a day). Report released 10 November 2025.

Status As of November 2025: the Health Ministry's 1403 report attributed 58,975 deaths to PM2.5; five former managers had been reported convicted under the Clean Air Law, with sentences undisclosed.

What?
Parliament assessed 22 of the 2017 Clean Air Law's 57 articles as weakly implemented; the Health Ministry attributed 58,975 deaths among people over 30 to PM2.5 in the Iranian year 1403. Zoomit
Where?
National, with focus on Tehran (35.69 N, 51.39 E) and Ahvaz (31.32 N, 48.67 E). Zoomit
When?
Law approved 16 July 2017; audits in 2023; Health Ministry report for the Iranian year 1403 released 10 November 2025. Ekhtebar
Who?
Gained
  • Municipalities — Collected green levies and retained Article 38 VAT revenues, often spent elsewhere, according to the Article 90 Commission Mizan (Judiciary news agency)
Lost
  • Five former managers — Convicted of dereliction of duty under the Clean Air Law, as stated by the head of the Tehran Province Judiciary Mehr News Agency
  • Iran (economy) — Economic loss from pollution deaths of about US$17.2 billion in 1403, per the Health Ministry Zoomit
Harmed
  • People and air in Ahvaz and Tehran — PM2.5 above the WHO 24-hour guideline on 362 days in Ahvaz and 350 in Tehran in 1403 Zoomit
  • Schoolchildren in Khuzestan and Tehran — In-person classes closed in Khuzestan and moved online in Tehran in November 2025 Zoomit
Why?
The Tehran judiciary head said the Department of Environment lacks the authority, staffing and structure to enforce the law, and that pollution is not a national priority; the Majlis Research Center listed 11 structural defects including no funding provisions. Mehr News Agency
How?
Funding is allocated in the annual budget (288 billion toman in 1401; US$4 million after a cut in the budget from March 2023); the Article 90 Commission put the minimum need at 206,000 billion toman. Mizan (Judiciary news agency)
6 of 6 questions answered from the record

What happened

The record, in order.

Iran's Clean Air Law was approved on 25 Tir 1396 (16 July 2017). In August 2023 the Majlis Research Center reviewed the law and its technical regulation: of 56 articles, 22 were weakly implemented, 17 moderately and 17 well; it recommended revising 17 of 34 articles and adding at least 10, and listed 11 structural defects including no funding provisions. The parliamentary Article 90 Commission, in a report presented on 27 June 2023, counted 57 articles, of which 22 were weak, 17 moderate and 18 well implemented. It said the Department of Environment was responsible for 60 provisions and fewer than 10% had been realised, that the Plan and Budget Organization had added a 320 billion rial line late and it was reportedly not used, that the Standards Organization had issued no directive blocking non-standard fuel imports, and that municipalities collected green levies and retained Article 38 VAT revenues but often spent them elsewhere.

The Health Ministry's national air-pollution report for the Iranian year 1403, released on 10 November 2025, attributed about 58,975 deaths among people over 30 to PM2.5, about 161 a day: 23% from ischemic heart disease, 21% lung cancer, 17% COPD, 15% stroke and 13% lower respiratory infections. Annual mean PM2.5 was 42 micrograms per cubic metre in Ahvaz, 34 in Isfahan, 32.9 in Tehran, 32 in Arak, 31 in Karaj and 29 in Mashhad, against 9 in Sanandaj and 11 in Rasht. Days above the WHO 24-hour guideline of 15 micrograms per cubic metre numbered 362 in Ahvaz, 351 in Arak, 350 in Tehran, 348 in Isfahan, 345 in Karaj, 335 in Mashhad, 268 in Qom, 193 in Kermanshah, 189 in Tabriz and 163 in Yazd.

The funding on record is small against the costs stated. RFE/RL and Al-Monitor reported that implementation funding in the budget for the year from March 2023 was cut from US$8 million to US$4 million. The Majlis Research Center said the 1401 budget allocated 288 billion toman for the law, that at least US$1–2 billion a year was needed for four years, and that bus-fleet renewal alone would cost about 500,000 billion toman. The Article 90 Commission put the minimum need at 206,000 billion toman nationwide, with a government share of 41,000 billion toman a year for nine metropolises, about 2.5% of the 1401 general budget. Mohsen Pirhadi, head of the Majlis urban-management faction, put the cost of one day of Tehran shutdown due to pollution at about 100 billion toman on 26 January 2024; the basis was not described.

Ali Alghasi-Mehr, head of the Tehran Province Judiciary, said on 3 December 2023 and 12 January 2025 that five former managers had been convicted of dereliction of duty under the Clean Air Law; sentences were not disclosed. He also said the Department of Environment lacked the authority, staffing and structure to enforce the law, that pollution was not a national priority, and that agencies interpreted the law in their own ways. In November 2025 primary and lower-secondary schools in Khuzestan closed to in-person classes and primary classes in Tehran moved online.

  1. 2017Clean Air Law approved (16 Jul)
  2. 2023RFE/RL and Al-Monitor report implementation funding cut from US$8 million to US$4 million; Article 90 Commission report (27 Jun); Majlis Research Center review (14 Aug); Tehran judiciary announces five managers convicted (3 Dec)
  3. 2024Cost of a Tehran shutdown day put at about 100 billion toman (26 Jan)
  4. 2025Judiciary head repeats that five managers were convicted (12 Jan); Health Ministry releases the 1403 report on 58,975 deaths (10 Nov); school closures in Khuzestan and Tehran (Nov)

What was said

Claims, in the words of those who made them.

“its enforcement requires the necessary budget”

Masoumeh Ebtekar, former head of the Department of Environment · January 2023 · translated from Persian · Al-Monitor

“We are denying the people a breath”

Mohammad Reza Sabaghian, member of parliament · 2023 · translated from Persian · RFE/RL

Where accounts differ

Each party's account, side by side, with its source. The record does not settle these points; it shows them.

Number of deaths attributable to air pollution
Government and regulators
Article 90 Commission (27 June 2023)

About 20,837 attributable deaths in 1400 in the studied cities.

Mizan (Judiciary news agency)
Government and regulators
Health Ministry (10 November 2025)

About 58,975 deaths among people over 30 attributed to PM2.5 in 1403.

Zoomit
Number of polluted days in Tehran in 1401
Government and regulators
Article 90 Commission

115 unhealthy-for-sensitive-groups days in 1401, up from 89 in 1399.

Mizan (Judiciary news agency)
Courts
Tehran Province Judiciary

114 polluted days in 1400 and 170 in 1401.

Mehr News Agency
How much of the law has been implemented
Researchers
Majlis Research Center (August 2023)

Of 56 articles, 22 weakly, 17 moderately and 17 well implemented.

Ecoiran
Government and regulators
Article 90 Commission (June 2023)

Of 57 articles, 22 weak, 17 moderate and 18 well implemented.

Mizan (Judiciary news agency)

How it looked

What was shown, beside what was recorded.

Shown

  • The law described as 'gathering dust for years', with about 21,000 deaths in 1400 (headline wording)
    Ecoiran, 14 August 2023, reporting the Majlis Research Center · Ecoiran

Recorded

  • Majlis Research Center (14 August 2023): of 56 articles in the law and its technical regulation, 22 weakly implemented, 17 moderately and 17 well; 17 of 34 articles to be revised and at least 10 added; 11 structural defects including no funding provisions.
  • Article 90 Commission (27 June 2023): of 57 articles, 22 weak, 17 moderate, 18 well implemented; Department of Environment responsible for 60 provisions with 'fewer than 10%' realised; Tehran unhealthy-for-sensitive-groups days rose from 89 (1399) to 115 (1401).
  • The Article 90 Commission stated that violations under Article 234 of the Majlis bylaws were still being pursued with the judicial authority (2023).
  • Tehran judiciary: Tehran had 114 polluted days in the Iranian year 1400 and 170 in 1401.
  • Health Ministry, national report for 1403: economic loss from pollution deaths about US$17.2 billion, US$47 million a day, about 1,394 thousand billion toman at the NIMA rate.
  • Article 90 Commission: about 20,837 attributable deaths in 1400 in the studied cities; economic cost about US$3.11 billion nationally in 1400 and about US$3.4 billion in Tehran (as printed).
  • RFE/RL (May 2023): the Tehran Prosecutor's Office charged five unidentified officials with failing to enforce Clean Air Act standards on vehicle emissions, gasoline quality and mazut-fuelled plants.
  • The Tehran judiciary's social-affairs office sent 94 letters and warnings to agencies including the Energy Ministry on mazut use since the Iranian year 1402.

Who gained

Money that reached nature, beside money that stayed elsewhere.

Reached nature or the ground

Not published
Priced damage to ecosystems from urban air pollution—
The figures on record are health and closure costs.

Gained elsewhere

Not totalled
Economic loss from air-pollution deaths, Iranian year 1403, Health Ministry≈ $17.2bn
Economic cost nationally, Iranian year 1400, Article 90 Commission≈ $3.1bn
Economic cost in Tehran, Iranian year 1400, Article 90 Commission (as printed)≈ $3.4bn
Clean Air Law implementation funding before the cut in the budget from March 2023$8m
Clean Air Law implementation funding after the cut$4m
Majlis Research Center: yearly need for four years≥ $1bn
At least US$1–2 billion a year.
Currency: USD · Window: 1400–1403. All figures cover the same period. * Estimate built from cited figures.

Responses on record

  • iran-judiciary (12 January 2025): The head of the Tehran Province Judiciary said the Department of Environment lacks the authority, staffing and structure to enforce the law, that pollution is not a national priority and that agencies interpret the law in their own way. · Mehr News Agency
  • iran-health-ministry (10 November 2025): Its deputy minister Alireza Raeisi presented the national report attributing about 58,975 deaths to PM2.5 in 1403. · Zoomit

In court and with insurers

Every proceeding and every insurer decision on record.

Lawsuits and rulings

  1. 2023–2023Claimant won
    Tehran prosecution of five former managers over Clean Air Law non-enforcement
    Tehran courts (as stated by the head of the Tehran Province Judiciary) · Criminal · Tehran Prosecutor's Office → Five former managers (not named in the sources)

    RFE/RL reported in May 2023 that the Tehran Prosecutor's Office had charged five unidentified officials. Ali Alghasi-Mehr, head of the Tehran Province Judiciary, said on 3 December 2023 and 12 January 2025 that five former managers had been indicted for abuse of position and convicted of dereliction of duty; sentences were not disclosed. Mehr News Agency

Insurers

No insurer decision on record.

What nature saw

Outcomes measured on the ground, and nature's note.

Nature's report opens this page. Below: further outcomes measured on the ground.

Deaths attributed to PM2.5
58,975
People over 30, Iranian year 1403, Health Ministry; about 161 a day
Annual mean PM2.5, Ahvaz
42 µg/m³
Highest of the provincial capitals listed; Tehran 32.9; Sanandaj 9
Days above the WHO 24-hour guideline
362 in Ahvaz
350 in Tehran, 351 in Arak, 348 in Isfahan
Articles weakly implemented
22 of 57
Article 90 Commission, June 2023

What we don't know

Undisclosed, unproven, untried: recorded as data.

Nature

  • Disputed Number of deaths attributable to air pollution
  • Disputed Number of polluted days in Tehran in 1401

Money

  • None on record Priced damage to ecosystems from urban air pollution — The figures on record are health and closure costs.

Accounts

  • Disputed How much of the law has been implemented

Record

  • Disputed Figures differ: deaths attributed to air pollution were 20,837 in 1400 in the studied cities (Article 90 Commission) and 58,975 in 1403 nationally for people over 30 (Health Ministry); the periods and populations differ.
  • Disputed Figures differ: the Article 90 Commission gave 115 unhealthy-for-sensitive-groups days in Tehran for 1401; the Tehran judiciary gave 170 polluted days.
  • Unclear Unclear: the Article 90 Commission's economic cost for Tehran (US$3.4 billion) is printed higher than its national figure (US$3.11 billion).
  • Not disclosed Insufficient: the Health Ministry's national report for 1403 is available through press coverage; the text of the 1403 national report is not published online.
  • Not disclosed Not disclosed: the calculation method behind the cost of closure days; Pirhadi's basis for 100 billion toman a day was not described.
  • Not disclosed Not disclosed: the names and sentences of the five managers convicted under the Clean Air Law.

Did the harm stop?

PM2.5 exceeded the WHO 24-hour guideline on 350 days in Tehran and 362 in Ahvaz in the Iranian year 1403 according to the Health Ministry; the sources record no end to the exceedances.

Who paid?

The Health Ministry's economic loss from pollution deaths in 1403 was about US$17.2 billion; implementation funding in the budget from March 2023 was cut from US$8 million to US$4 million; five former managers were reported convicted, with sentences undisclosed.

Sources

Voices on record: — Company or project— Government and regulators— Courts✓ Press and investigations— Communities and civil society— Researchers✓ Standard-setters and registries

Standard-setters and registries

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