Prime Quality Product Sourcing. International Support to Business Owners & Purchasing Departments

EXPORT ( TRADE / TRANSFER ) COMPLIANCE

dual use products

No, they relate. According to the UK’s EXPORT CONTROL ACT OF 2002

( https://www.legislation.gov.uk/ukpga/2002/28/contents )

in Schedule 1, you can see that Export and Trade controls may be imposed in relation to on goods from which military technology can be derived. We all know that military technology can derive from either the military ( specially designed, modified, manufactured for military use ) products or the commercial products ( commercial products that can be used for military purposes – the actual nature of dual use products ), therefore, all commercial products are subject to controls.

 

If it is unknown then suppliers have to apply. If they apply they take all the risks as discussed below. That is an excellent reason why you can cooperate with Utility Metals. Utility Metals pays emphasis on if goods are controlled and where. If they are controlled it will not apply ( except few except cases on NATO projects, etc. )

If they are fined, you bet they will. Not following laws either because they simply are not aware of them or in case they do it on purpose are not the best options. 

BY ALL MEANS YES, Utility Metals although is not seeking to deal with goods that are controlled, it has devoted years in the matter of export compliance and loves to exchange ideas and views on this matter. Utility Metals has made studies in the past for export compliance ( only for cases relating to the metals and plastics industry ) and has provided them to the UK Export Control Organisation, to the Alpha Initiative and the European Institute of Export Compliance ( E.I.F.E.C. ). Additionally any institution ( commercial or state ) related to export compliance would be more than welcomed to contact U.M. Moreover U.M. follows its own private strict Exports Compliance Policy and a much shorter version, a public one, is available for viewing by following this link: https://u-metals.com/wp-content/uploads/2019/05/U.M.-Export-Compliance-Policy-Public-May-2019.pdf

It is time consuming, so it is costly. An application for a license needs from many hours to many days to be properly prepared. This is translated to monetary cost that if passed on the product selling price this becomes more expensive. Additional it does not wish any application to be denied. An application for a license may be turned down by the export control organisation ( in whichever EU country not just in the UK ) for whatever reason relating to the customer – provided of course that the supplier has done nothing wrong or the supplier may have prepared an excellent and a well written application. Utility Metals would not be interested in preparing a license application that would possibly be turned down. Don’t forget that if a customer needs goods that are controlled, the application for a license is prepared by the supplier not the customer, therefore, U.M. woud not be interested in preparing a license that would possibly be turned down ( even with a very low probability for such a scenario ), for reasons relating to the customer and not for reasons relating to U.M. as U.M. knows how to prepare applications and U.M. knows in the cases where the legislation is clear, if goods are controlled and where.

No. Utility Metals is not seeking to sell products that may need a license. First of all military projects are not a priority for Utility Metals. Utility Metals sells also to defense but the vast majority of past sales of Utility Metals was to other industries such HO.RE.CA, Construction, Shipping, Architecture, CNC for commercial applications etc. Moreover Utility Metals has applied for an export license only for cases relating to the German Army, so unless your project is for the US, UK, German, French, Austrian, Swedish Army, etc. or for some NATO project,  Utility Metals will not be able to accept handling your inquiry. Also it is known that Utility Metals does not handle inquiries for the following end uses ie, nuclear, labs for biological applications, missiles, ammunitions, launching platforms for missiles, armoring of civilian vehicles, aircraft engines and other

Contact an export compliance company to handle your inquiry. There is a cost.

Hire a lawyer specializing in export compliance matters. There are legal fees

Employ a dedicated exports compliance officer in your company. For an average cost estimate per year, there is some information on the web, check in a search engine.

Go alone. Study the laws, again and again and again. Laws are not just your local laws, there are UN regulations, US regulations, EU regulations and although they speak for the same thing export compliance laws in different countries are not of exact match. Check if you have understood the laws, recheck since you are not a lawyer. Attend conferences and seminars by Export Control Organizations, There is some cost. Watch webinars online. Contact the helpline of the Export Control Organization in your country. Read again and again and again online articles. Discuss and connect with people from Export Control Associations. Join Social media groups for Export Compliance. There is quite some effort involved, it is translated to cost but it also translated to a large profit for you as you will in much better position to understand and operate under an international export compliance system. You will save much more time in the future for this and be in position to get or accept more orders for products that are possibly controlled and previously you were declining such orders. 

If you do not have time or funds for any of the above solutions and you are unsure what to do and whether your products are controlled and where

then

Contact Utility Metals. You will then know if goods are controlled. If they are controlled ( and they are not any part of any NATO project ) Utility Metals will not handle the inquiry.
If it is unknown if the goods are controlled and an application to the export control organization has to be made, U.M. will not proceed with the application. If they are not controlled then Utility Metals would gladly examine to handle it thus saving you a lot of money. Still even if U.M. will save you a lot of money you are well advised to be proactive with export compliance and try to find time to deal and be more educated on this topic.

At all cases you are most strongly advised to take the matter of export compliance very seriously and always contact suppliers that handle this responsibly. You must assist suppliers with as much as possible information in your inquiries ie. if the project is military and if it is for what project ie type of military airplane or type of military vehicle,  if goods are to be -exported outside your home country, if goods are to be machined in your country, what is the exact end application i.e.: architectural facades or construction pipe etc. It is best if you as a customer also contact and ask and insist for such information from your customer so you can inform the supplier accordingly to assist him in deciding whether goods are controlled and where.

Why companies pay taxes ? Why they submit annual returns ? Export Compliance is one more legal requirement that all companies have to follow. It is also as discussed above, a moral obligation to contribute in the fight against WMD

Yes, only for projects relating to the German army. Only in one case an exports license had to be issued. All rest of cases were of NLR products ( No License Required as were determined by the U.K. Export Control Organisation )

It is best for Utility metals not to comment on what your supplier does ( except rare cases where it is more than evident that a supplier does not follow very strict legislation ). In this webpage all information Utility Metals provides is supported with weblinks of mostly governmental or international authorities documentation. Utility Metals is in position at any time to provide to any Exports Control Organization in the E.U. the reasons behind any action in determining if a product is controlled or not i.e: by stating what legislation has been viewed and the logical tree behind any conclusion.

Utility Metals would never be against Exports Compliance. Constructive criticism is only for purposes of building a better and industry friendly exports compliance system. These international organisations active in export compliance have presented successes in the fight against proliferation of WMD by the time most of us were not even born. The progress has been very good in the last years, yet, this large effort has to continue.

This is obvious. If the one supplier asks you for an undertaking end-use letter and he has to apply for a license to the Exports Control Organization ( E.C.O. ) of the country where his company is registered, then that means the supplier knows exactly if the goods he sells are controlled and where. That is verified by the E.C.O. that issues the license, therefore, both the supplier and E.C.O. follow strictly the current legislation, whereas, the supplier that does not ask for a license does not ( not necessarily due to intention but perhaps due to lack of knowledge of the current legislation ). To which company do you want to place your order ? The one following the legislation or to the one that does not ?

Again here, what do you want ? Nobody wants to lose orders. Do you want to lose an order but at the same time knowing you had followed the legislation or you want to win an order by not following the legislation ( possible fines, closing of the business, imprisonment etc. ) ? Up to you.

This is nothing more or nothing less than U.M. following the standard Compliance Code of Practice of March 2010, by the U.K.’s Department for Business Innovation & Skills, the relevant link can be followed here https://www.gov.uk/government/publications/compliance-code-of-practice
, as well as following international practices in export compliance.

Yes, according to the following link:

https://www.gov.uk/guidance/import-controls#import-licensing

IMPORT CONTROLS

Because of their effect on the EU single market, EU import controls are directly applicable in all EU member states, so further national legislation is not needed. They are imposed when the EU needs to carry out a measure agreed within the EU or internationally (for example, a UN Security Council resolution), or to carry out an EU trade policy decision.

You will see on the same webpage that there is ”EU prior surveillance monitoring regime on imports of aluminium and steel.” Still this involves only a limited number of countries and some quotas in some TARIC numbers.

You can know that U.M. does not only follow legislation about Export Controls but also about Import Controls

As you have seen in the previous Questions/Answers, there is a dual legislation, National and E.U. ( and more ie U.N. etc. ) that examines the route of the products from the producer or wholesaler to the end destination ( first end destination and other possible end destinations ) and you see also that there are import controls as well, therefore, all the supply chain ( seller/transporter/buyer ) is responsible for a sale or sales of a product.

Place your order with Utility Metals so you can know whether the products you need are controlled or not.

BY ALL MEANS YES ! Utility Metals for the products it inquires or buys from you, would be very glad to explain exactly where the products are controlled OR are not controlled.

If Utility Metals would accept to sign this letter ? But, it has already signed several times this or similar letters coming from export compliance departments of U.K. companies with U.S. interests and U.M. is very happy doing so.

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Company:
UTILITY METALS UK LTD
Registered in England & Wales
Registered & Trading Address:
483 Green Lanes, Palmers Green,
London, N13 4BS, U.K.
Company #: 08383517,
VAT: GB176985149,
EORI customs #: GB176985149000

 

Products:

Stainless Steels
Aluminium
Non Alloyed & Alloyed Steels
Copper & Brass
Nickel and Nickel Alloys
Titanium
Industrial Plastics

 

Last Updated:
May 24 / 2019, 17:00 h. (GMT  + 2 h.),
Utility Metals UK Ltd
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