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Export Compliance for our Products End-Use
Carbon Fiber Composite Materials: Export Control
Fight Against the Proliferation of Weapons
Our carbon fibers and composite materials, and associated technologies are considered “dual-use” goods, as they can be used for civilian or military purposes.
The French State and the European Union have implemented export controls for these products and technologies to combat the proliferation of weapons. This regulation applies particularly to weapons of mass destruction: nuclear, chemical or biological.
Toray Carbon Fibers Europe's Commitment
For many years, Toray Industries and all of its relevant subsidiaries, such as Toray Carbon Fibers Europe, have committed to ensuring strict control over the use of carbon fibers and composite materials.
In addition to the regulations in force in each EU member country, all orders placed by our customers must include a signed letter of assurance (LOA) specifying the product’s end use.
This document must be approved by our Export Control Department before the order is shipped.
Regulatory Provisions and International Cooperation
Goods designated as ‘sensitive exports’ are subject to specific export control agreements between nation-states. The agreements include:
- Common rules for evaluating export license applications;
- Lists of controlled dual-use goods and technologies.
EU Council Regulation (EC) 428/2009 of 5 May 2009 is directly applicable by law in all EU member countries. Annex I sets out the list of dual-use goods and technologies controlled under international regulations. This list is updated annually.
The Main International Regulations are:
- The 1987 Missile Technology Control Regime (MTCR);
- The 1974 Nuclear Suppliers Groupe (NSG);
- The 1995 Wassenaar Arrangement (WA) on the EU Export Control on Conventional Arms and Dual-Use Goods and Technologies;
- The 1985 Australia Group (AG) on the Guidelines for Transfers of Sensitive Chemical or Biological Items;
- The 1993 Organisation for the Prohibition of Chemical Weapons (OPCW);
- The 1972 Biological Weapons Convention (BWC).
Warning to Oour Customers
Companies that supply dual-use goods could unintentionally enable the production of weapons of mass destruction. It is essential to check the end use of your goods before shipping them to your customers.
Here are some warning signals that should alert you:
- Countries or end users under sanctions or restrictions: Check the list of sanctions or restrictions issued by the relevant country from which the goods are exported;
- Lack of clarity: Difficulty in finding information about the customer, reluctance of the customer to provide information about the end-use of the goods. Verify the identity of the end user and the end-use of the product;
- Lack of coherency: The quantity ordered is not in line with the declared end use, or the technical characteristics of the ordered product are unsuitable for the end-use thereof;
- An illogical supply chain: Request for unusual arrangements for shipping, the declared end user is a trading company, a distributor that does not directly transform your product;
- The product has a known dual-use as a , military or sensitive application;
- The payment conditions are unusual and exceptionally favourable.
