Scrutiny of Arms Export Controls (2009): UK Strategic Export Controls Annual Report 2007, Quarterly Reports for 2008, licensing policy and review of export control legislation - Committees on Arms Export Controls Contents


Memorandum from the Export Group for Aerospace & Defence

  I believe that the Committee asked for further details of the problems that our companies have reported encountering when seeking End-User Undertakings from the UK Ministry of Defence; I must apologise for the delay in addressing this issue, but I have been taking soundings of our Members to try to get a better feel of the scale of the problem.

  It is clear that this is a bit of an on-going problem for UK Industry, depending on with whom they are liaising within the UK MoD, and on which project, as the extent of their knowledge and understanding on export control issues is highly variable—some IPTs are exceptionally good and proficient, whilst others are not, and require the always effective and knowledgeable input from the Export Policy and Assurance (EPA), formerly known as "Directorate of Export Services Policy (DESP)", at the UK MoD to intercede on Industry's behalf.

  It is clear that the exact definitions of "End-User" and "Consignee" are greatly misunderstood within some parts of HMG who have few dealings with export licensing matters on a daily basis. In some instances, involving intra-EU trade, the IPTs have been known to refuse point blank to sign EUUs, citing the EU Directive as giving a total blanket exemption to them from having to do so. However, this perceived exemption is seemingly totally unknown to the Governments of other EU Member States, who still demand that their exporters need to provide an EUU.

  Some internal awareness training of IPTs on the need for EUUs, and how to complete them, is clearly needed to rectify this issue.

  On another matter, I have heard that during the UK Government's own oral evidence session, back in April 2009, comments were made about the possible inclusion of anti-vehicle land mines under Category B of the UK's Trade Controls. There follows the text of an e-mail which I sent to the Export Control Organisation, on 22nd December 2008, on this issue:

    I can confirm that I have (very hurriedly) taken some Industry soundings on this issue, and we would totally support the NGOs' stance on this matter.

    The only UK manufacturer that I can readily identify is BAE Systems Land Systems Division, and the impact on their supply chain activities would be minimal.

    Our initial thoughts in our discussions with the NGOs was that the new Category B should be focused on, to put it very simply (because we in Industry is not very bright), "anything that goes 'bang'"—ie all weapons and munitions—as this is the area of greater concern, over which HMG should want to have the closest of control and scrutiny. Clearly anti-vehicle mines (as with all such mines) should fall within this definition.

    It should be, as stated, a relatively minimal and uncontroversial in its impact on UK Industry.

    These items are also relatively easily, inexpensively and readily "traded"—and much more so than long-range missiles and UAVs, to our way of thinking—and, therefore, are much more likely to be the subject of "trade" activities.

  Therefore, we would have no objections to this being re-examined by the ECO.

22 May 2009





 
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