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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