APPENDIX 12
Supplementary memorandum from Saferworld
I am writing to clarify why Saferworld believes
that it is important that reference to military list (ML) ratings
are re-instated in the Annual Report on Strategic Exports.
Saferworld welcomed the publication of the Government's
2000 UK Annual Report on Strategic Exports, which was the most
detailed annual report on arms exports that has been published.
However, in the 2000 Report, references to military list (ML)
ratings have been dropped entirely from the information on SIELs
issued. This was on the basis that as dual-use items are now described,
ML ratings are redundant. However, the ML ratings make a useful
contribution to the "user-friendliness" of the report,
as they are useful in alerting observers to certain categories
of goods which may raise concerns; it can be difficult to locate
such types of item in amongst the often extensive lists of summary
descriptions, especially as the imprecise nature of many of the
descriptions makes evaluation difficult. As such, we consider
this omission as a significant backward step and would recommend
that the summarising country-by-country tables of SIELs issued
under each ML rating should be reinstated in the 2001 report.
Furthermore, the ML-rating information available in the first
three Annual Reports could be used to identify trends over time
in licences issued, however through their absence from the 2000
report this opportunity has been lost. It would therefore be useful
not only to reinstate this info in the 2001 report, but also to
retrospectively provide it for the year 2000.
A more transparent system of reporting would
require that for each licence issued, both the ML rating and a
summary description of the items for export be included, with
the description precise enough to enable a judgement to be made
as to whether the export meets the export guidelines. For example,
whereas the description "machine gun" does meet this
test, "aircraft spares" or "electronic equipment"
could both include a range of equipment that could be relatively
benign, or equally could be very sophisticated and of potential
concern. There is a big difference between licensing exports of
two-way radios and licensing advanced computer systems for weapons
targeting. Generic terms defy analysis and should therefore not
be used. Furthermore, future Annual Reports should use the most
precise ML rating possible through the use of sub-categories.
For example, the licensing of cargo parachutes would carry the
rating ML10.a.2.
26 April 2002
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