APPENDIX 16
Memorandum submitted by BLWA Ltd
WHITE PAPER ON STRATEGIC EXPORT CONTROLS
Thank you for your letter of 1 July from Miss
Bridget Butt enclosing the above White Paper. BLWA Ltd is the
Trade Association for the Laboratory Supply Industry and represents
manufacturers and distributors providing products for use in analytical,
research and pathology laboratories throughout the world. Many
of our members supply products therefore that are covered by the
dual use technology controls. The fact that such products can
easily be used for legitimate peaceful as well as military purposes
has always been a problem for our members as well as the regulatory
authorities. In our industry quantities of products are usually
small or the dimensions are small thereby often taking them outside
the dual use regulations though not always. We would like to make
certain comments on the issues raised in the White Paper.
End of Use Monitoring
This has always been a difficult subject. The
normal pattern of trade in our industry is to sell to laboratory
supply dealers in the recipient country. At the time of importation
the dealer may well not be able to state who the end users will
be. Scientific glassware and laboratory reagents are virtual commodity
products with a multitude of uses. Examples covered by dual use
controls include glass condensers, anaerobic jars and depleted
uranium compounds.
Licensing Authorities
We note that the Government has decided that
the licensing authority should remain within the DTI. It is logical
that this should remain centralised and that no part should be
transferred, for example, to the Ministry of Defence. Accepting
this logic can we ask that consideration be given to centralising
within the DTI all export licensing. Currently our members are
faced with certain licences having to be obtained from the Ministry
of Agriculture and/or the Home Office. In an extreme example it
could happen that a product might need three different licences
from three different departments. We believe this is unworkable
both for the authorities and industry.
Dual Use Goods
As is stated in the paper these are covered
by the EC Dual-Use Goods Regulation, and is the main area of our
interest. Any amendment to the 1939 Act should allow obviously
for changes in this area to be covered by secondary legislation.
We would wish to continue to be consulted on any changes envisaged
in this area.
17 July 1998
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