This report was written
for the International Action Network on Small Arms and for GRIP as part
of the programme ‘Observatory on global weapons production and transfers’
by the Walloon Region, Belgium. The author would like to thank the contacted
governmental officials and representatives of companies in the defence industry
in Germany, France, and Belgium, who assisted him in this research. The
here presented opinions are those of the author alone and do not necessarily
reflect the official position of the Walloon Region or the contacted ministries
and companies. Any remaining errors are his.
European Union member states are expected to adopt
in the near future a revised EU Code of Conduct on Arms Exports to further
develop and strengthen their co-operation in the area of export controls on
military equipment. One expected development is a tightening of the Code’s
standards related to limiting the risk of diversions of military equipment.
In particular, the revised Code will strengthen standards for the assessment
of diversion risks in relation to exports of production capacities and finished
goods derived from these. This includes capacities exported for the purposes
of licensed production of military equipment in third countries. The revised
Code will thereby address an issue area that has long been identified by arms
control advocates as requiring greater scrutiny and governmental efforts.
This paper assesses the expected advances in controls
on exports of production capacities under the renamed EU Code of Conduct on
Exports of Military Equipment. The paper starts by highlighting the particular
proliferation risks associated with exports of production capacities. It then
turns to a review of good practices in national and multilateral counter-proliferation
policies in Europe. It is argued that the revised Code makes important and
welcome advances but falls short of existing good practices and requirements
in several aspects. Further, there is significant scope for strengthening
co-operation between EU member states to assist in responsible licensing for
exports of production capacities for military equipment.
The paper recommends that EU member states further
develop common understandings on export controls on military production capacities.
In particular, the revised EU Code should be complemented with a common understanding
that exports of production capacities will be subject to strict end-use conditions,
including mandatory end user and end-use declarations and sanctions for violations
thereof. Further, EU member states should consider developing guidelines to
assist national export authorities in the responsible implementation of the
revised EU Code’s provisions to limit diversion risks.
2. Proliferation risks
associated with capacity transfers
Production capacities for military equipment cover
technology and equipment required for the manufacture of components or fully
assembled conventional arms and ammunition. Exports of production capacities,
including deals for licensed production of military equipment abroad, are
a well established practice in the international arms market. For example,
more than 90 % of production facilities in the world for small arms and light
weapons (SALW) ammunition for military and law enforcement markets are estimated
to be equipped with production and assembly lines provided by companies in
Germany, France, and Belgium. 
On the supply side, governments may have an interest
to support political allies in efforts to establish, maintain, or modernise
domestic arms industries. In addition, there may be commercial interests by
providers of production equipment and technology to open up foreign markets
and establish the specific good in these markets.
To illustrate, the Belgian FN Herstal, a principal
global producer of small arms and light weapons, operates production facilities
in Belgium, the USA, and Portugal. In addition, it has entered into licensed
production deals or supported foreign producers with technology and production
equipment in more than 20 Latin American, African, and South-East Asian countries.
 FN Herstal itself was formed in 1889 to produce 150,000 infantry
rifles for the Belgian armed forces under license from the German Mauser Werke.
Similarly, the German Heckler & Koch (H&K)
has had its popular G3 assault rifle being produced in, next to its German,
British, and US production facilities, under license in more than 15 countries
in Latin America, Europe, the Middle East and Far East, as well as South-East
On the demand side, many governments prefer a
domestic capacity for the production of the models and types of arms and weapons
employed by the national armed forces. The USA, for example, has consistently
required that military small arms based on foreign designs and employed by
the US armed forces are produced domestically.  Some states may also have an
interest to establish or upgrade their domestic production capacities so as
to actively participate in the international arms market.
between transfers of production equipment and diversion risks
Regrettably, the increase in the number of manufacturers
of military equipment over the last decades, which is largely the result of
transfers of production capacity, has also led to an increase in the number
of potential sources of arms proliferation. In particular, production centres
may be located in states, which have not in place control systems that ensure
the responsible management of military equipment. This can greatly contribute
to diversions from production centres, stockpiles, and during transfers. In
addition, recipient countries may not abide to given end-use declarations,
where these were required, and re-export production capacities or export finished
goods to undesirable recipients.
2.1.1 The case of AK assault
The relation between transfers of production capacities
and proliferation risks, especially insofar as related to SALW, can be illustrated
with the example of the Kalashnikov assault rifle (AK). This rifle type was
originally designed in the 1940s in the Soviet Union. By now, the AK
has more than 160 derivatives and is “the world’s most widely distributed
single weapon model”. While no longer produced in its country of origin, rifles
of the AK family have been produced in 19 countries, and “estimates of the
total number of AKs in circulation range as high as 100 million”.  Importantly, this widely chosen
instrument of violence in armed conflicts is produced beyond any control by
the Russian Federation. This has been made possible by, among other, a lack
of efforts by Soviet Union officials to strictly controls transfers of production
designs for AK rifles.
2.1.2 Experiences of Germany
A further illustrative example is the experience
by Germany. It actively supported in the 1960s and 70s the build-up of domestic
production capacities in newly independent states to allow these to meet their
national security needs. This included the build-up of small arms production
capacities in Pakistan and Iran through the authorisation of licensed production
deals for the H&K assault rifle G3. The deals were conditional on these
weapons being only for domestic consumption by national armed forces.  However, subsequent regime changes
in these countries resulted in new governments, which considered themselves
no longer bound by end-use obligations given by the preceding regimes.
Germany now faces the situation that weapons from
production centres it once helped build are finding their way into armed conflict
and crime. For example, in 2001, Pakistan reportedly transferred domestically
produced H&K assault rifles to Sri Lanka. Germany would not have been
likely to authorise an export this equipment to Sri Lanka at that time.  Similarly, Iran is reputed to
be a source of assault rifle proliferation based on production capacities
once imported by Germany. Also, in March 2003, the Serbian Prime Minister
Zoran Djindjic was assassinated with a H&K sniper rifle. The analysis
of the rifle by the German federal criminal police revealed that it had been
pieced together from components produced in several countries abroad that
previously imported German production capacities.
2.2 Risks of
diversion associated with exports of production capacities
It deserves emphasis that there exist proliferation
concerns regarding exports of production capacities, which are broader than
those related to exports of finished components or fully assembled military
equipment. That is, the establishment, maintenance, or upgrading of production
facilities abroad implies the risk not only of diversion of a finite number
of exported finished goods, but of contributing to sources of continued diversions
for decades to come. This risk is especially pronounced with regards to production
centres for ammunition for SALW. That is, while a diverted SALW may be (mis-)used
on a repeated basis, diverted ammunition will generally be (mis-)used only
once. This implies a continued demand for illicit SALW ammunition by those
who cannot acquire required ammunition on the legal arms markets. Poorly controlled
production centres for SALW ammunition can consequently become proliferation
sources of particular concern.
2.2.1 Limited options for
Further, there is the critical issue of limited
control options by exporting states regarding the compliance by end users
with end-use assurance where these were required. For example, with no control
over output and transfers by SALW production centres Germany once helped established,
Germany’s scope for measures to counter proliferation from these centres is
largely restricted to denying transfers of machine spare parts. This has reportedly
led to a diminution of the quality of the weapons derived from the production
capacities originally transferred by Germany, though not a stop of production.
Another example is given by efforts by Belgium
and other foreign officials to inspect the Eldoret production facility for
SALW and SALW ammunition in Kenya. This facility was established with the
help of Belgian companies in the mid and late 1990s. So far however outside
inspections of the Eldoret facility to verify compliance with Kenyan end-use
assurances have not been granted by the Kenyan government [see Box 1].
Box 1: The Eldoret
The importance of adequate
national control measures in recipient countries is underlined by the
example of the Kenyan Eldoret facility. The facility was equipped in
the 1990s by FN Herstal for the manufacture of military small arms ammunition.
The Kenyan government provided the Belgian authorities with written
assurances that ammunition produced at this plant will not be exported
to belligerent parties in the Great Lakes region.
There remains concern however
that Kenya has not yet in place a national control system allowing national
authorities to enforce this assurance. Thus, there have been repeated
accusations that ammunition produced at Eldoret found its way onto illicit
regional markets. Concern is further sustained by the fact that the
reported annual output capacity of 20 million rounds at Eldoret greatly
exceeds the national defence requirements of the Kenyan armed forces
of an estimated two to three million rounds.
In addition, current levels
of transparency in Kenya on actual production output, transfers and
end users of ammunition produced at Eldoret are low. They do not allow
for adequate scrutiny by the Kenyan parliament, Kenya’s civil society,
and others of the government’s production and transfer practices. They
therefore also do not allow for independent verification that ammunition
coming from Eldoret is responsibly managed and secured against diversions.
1. See, for example, Amnesty International (2004) Undermining
Global Security. London, AI, p.35f.
2. see East African (2003) Kenya Will Not Close
Eldoret Bullet Factory, Says Murungaru. Available at http://www.nationaudio.com/News/EastAfrican/20102003/Regional/Regional35.html
, accessed 22 April 2005.
Risks of diversion of production capacities and reverse engineering
One particular diversion
risk associated with transfers of production capacities relates to the diversion
of the capacities themselves. For example, an importer of production machinery
and designs may re-transfer the capacities to undesirable third parties. Further,
designs for production equipment may be duplicated by the recipient through
cloning or reverse-engineering. South Africa, for example, is reported to
have cloned imported production equipment for SALW ammunition so as to increase
national output capacities and mitigate the effects of the arms embargo that
was imposed on South Africa’s past apartheid regime.
 Such cloning of equipment and construction designs based on well-established
production technologies does not pose significant technical challenges and
requires little apart from trained engineers.
Risks of diversion of finished goods
of production capacities can imply risks of diversions of finished goods derived
from the imported technology or equipment. In particular, a risk exists that
recipient states do not have in place the domestic controls and mechanisms
required to ensure the responsible management of goods derived from imported
production capacities. Responsible management entails, among other, the existence
of adequately mandated, trained and equipped national authorities; adequate
record-keeping requirements for manufacturers and subsequent domestic recipients
of finished goods; appropriate stockpile security measures; and physical verification
of records and production, stockpiles and transfers. These measures are essential
to combat diversions of finished goods through loss, theft, neglect, or corruption.
As mentioned, importers
may also export finished goods to end users considered as undesirable by the
state which transferred the production capacities. For example, in 1999, the
Turkish state-owned enterprise MKEK exported 500 submachine guns, manufactured
as part of a British licensed production deal, to the Indonesian police. The
transfer took place at a time when the UK would most likely not have granted
an export of such weapons to Indonesia.  Further, importers may flaunt assurances
given to the authorities of the exporting state regarding the end use of the
derived finished goods. An early example was given by FN Herstal, when it
continued in the 1890s to produce Mauser rifles beyond the original production
European export standards to limit risks of diversions
EU Code of Conduct on Arms Exports
A key element in European
counter-proliferation policies is provided by the EU Code of Conduct on Arms
Exports. Adopted in 1998, the Code’s criterion seven stipulates that member
states will consider when assessing export licenses the ‘existence of a risk
that the equipment will be diverted within the buyer country or re-exported
under undesirable conditions’. Specifically, member states will consider elements
such as the ‘legitimate defence and domestic security interests of the recipient
country’; ‘the technical capability of the recipient country to use the equipment’;
and the ‘capability of the recipient country to exercise effective export
This commitment was
complemented in 2002 by an agreement among EU member states on the principle
that the proliferation of the technology and means to produce military equipment
requires special attention. This included an agreement to consider when assessing
licenses for exports of production capacities ‘the potential use of the finished
product in the country of production and of the risk that the finished product
might be diverted or exported to an undesirable end user’. 
Expected advances under the revised EU Code on Arms Exports
The revised EU Code
of Conduct on Exports of Military Equipment is expected to considerably strengthen
standards in the EU on export licensing for items on the EU Common Military
List. In particular, the revised EU Code is expected to clearly stipulate
that applications for licensed production overseas will be assessed in the
same way as license applications for physical transfers, that is, against
the criteria of the EU Code. 
Further, the principle
would be codified that member states not only assess the risk of diversion
regarding exported production equipment, but also of the derived finished
goods. This would be coupled with the principle of prior knowledge by exporting
states of the end user and end-use of the equipment and derived goods. In
addition, member states would commit to assessing additional elements when
assessing diversion risks for exported equipment.
 The additional elements would include the record of the recipient
country in respecting given end-use assurances, the risk that exported items
would be diverted to individual terrorists, and the risk of reverse-engineering.
OSCE Document on SALW
As states member to
the 2000 OSCE Document on Small Arms and Light Weapons, EU member states also
committed to not licensing export licenses for SALW if “there is a clear risk
that the small arms in question might … be either re-sold (or otherwise diverted)
within the recipient country or reexported” under undesirable conditions.
This covers exports of technology for the design and production of small arms
and light weapons. Importantly, OSCE member states committed to take into
account for export licensing “the stockpile management and security procedures
of a potential recipient country”.
Further, member states
committed to “make every effort … that licensing agreements for small arms
production concluded with manufacturers located outside their territory will
contain, where appropriate, a clause applying the [criteria stipulated in
the OSCE Document on SALW] to any exports of small arms manufactured under
licence in that agreement.” 
OSCE Principles on export controls on MANPADS
Even more specific
are the controls for transfers of production capacities EU member states committed
to under the OSCE Principles for Export Controls of man-portable air defence
systems (MANPADS). These principles were adopted in 2004 in recognition of
the particular threats posed by posed by proliferation and misuse of MANPADS.
The controls stipulated in these principles apply to, among other, transfers
of capacities for the development, production, assembly, maintenance and operation
In particular, transfers
of production capacities will only be authorised to foreign governments and
on the condition of an end user certificate containing a clause prohibiting
re-exports without prior consent.
 Further, exporting governments will take into account the “potential
for diversion or misuse in the recipient country; the recipient government’s
ability and willingness to protect against unauthorized re-transfers, loss,
theft and diversion; and the adequacy and effectiveness of the physical security
arrangements of the recipient government for the protection of military property,
facilities, holdings, and inventories.”
National controls in EU member states
In response to increased
concern about the easy availability for undesirable end users of SALW and
other military equipment, many states have adopted on national levels strengthened
export standards for production capacities. For example, France is reputed
to have significantly restricted in recent years the range of permissible
export destinations for production equipment for SALW and SALW ammunition.
This has had important ramifications for the main French provider of SALW
ammunition production equipment. With its range of permissible destinations
increasingly restricted, the company is adopting an increasing focus on servicing
established clients in countries considered by French export authorities to
be in a position to adequately ensure responsible national management of derived
finished goods. 
Control standards in Germany
Good practices are
also found in Germany. It tightened its relevant controls in its Political
Guidelines for the Export of Military Equipment of 19 January 2000.
 In particular, exports of ‘weapons of war’ and related production
capacities are, as a matter of principle, only granted to governmental end
users in European Union or NATO member states, or ‘NATO-equated’ countries,
that is Australia, New Zealand, Switzerland and Japan. In addition, the guidelines
specify that the ability of the recipient country to exercise effective export
controls on the technology or production equipment as well as of derived goods
will be considered according to strict standards. 
this restrictive policy in 2003 by stating that export licenses for technology
and production equipment are denied, as a matter of principle, where the export
would open new production lines for small arms and ammunition in non-EU, NATO
or ‘NATO-equated’ countries. 
Further, Germany requires
an end-use certificate identifying the end user and end-use of derived finished
goods. Signatories of these declarations must commit to neither pass on to
another company transferred production capacities nor to make related production
knowledge available to third parties. Signatories must further commit to neither
re-export imported production capacities nor to export derived goods without
written approval of the German authorities.
Similarly to the main
French provider of SALW ammunition equipment, the main German provider of
such equipment has been forced by the new and more restrictive German export
policies to downscale its operations and focus on the supply of established
clients in countries considered by German export authorities to be able to
ensure compliance with end-use assurances.
Scope for further development of European standards
Recent efforts by states
to strengthen counter-proliferation standards in their arms export controls
are a welcome development. In particular, the revised EU Code of Conduct on
Export of Military Equipment makes important advances by firmly integrating
exports of production capacities into broader export controls on military
equipment; by specifying in greater detail the elements to be considered in
the assessment of risks of diversions; and by coupling such exports with the
principle of prior knowledge of the end user of both the production capacities
and the derived goods.
Despite advances though,
the revised Code still falls short of certain existing good practices adopted
by EU member states in relation to for example SALW and particularly MANPADS.
For example, the revised Code will not stipulate the need to assess the recipient
country’s ability and willingness to protect against unauthorised re-transfers,
loss, theft and diversion. The revised Code will further fail to stipulate
the need to assess the adequacy and effectiveness of the physical security
arrangements of the recipient country for the protection of military property,
facilities, holdings, and inventories. Also, no reference is made to the emerging
minimal standard that transfers of production capacities will be conditional
on strict end user obligations regarding the production capacities and goods
derived from these.
Facilitating risk assessment at licensing stage
A fundamental problem
often faced by national export authorities is a lack of readily available
and reliable information on the end user and end-use for production capacities
and derived goods. Regrettably, there seems a tendency at times to make up
the lack of information by emphasising that the recipient has given end-use
assurances regarding the production equipment and derived finished goods.
However, it would seem ill-advised to scrutinise at the licensing stage only
a recipient’s willingness to conform to end-use obligations, but not also
the recipient’s capacity to ensure compliance with the obligations. ‘Merely’
requiring an end user certificate without further obtaining relevant information
of the recipient’s situation therefore seems hardly sufficient.
Where border-line cases
are concerned, national authorities should either not grant the license on
precautionary grounds, or seek relevant information more proactively than
often seems the case. Facilitating adequate assessments by national authorities
of diversion risks could entail guidelines on how to assess elements such
as a recipient’s country capability to exert effective export controls. Other
elements, such as assessing the recipient’s capability to prevent undesirable
diversions, could also be usefully elaborated on. In addition, states should
make greater use of their capacities to undertake thorough pre-licensing checks
for exports of production capacities [see Box 2]. It would also be desirable
that member states share experiences of their national experiences in such
2: Use of expert missions at licensing stage
recent example for thorough checks at the licensing stage was given
by the government of the Walloon Region in Belgium in the context of
an export license application for a production line for SALW ammunition
to Tanzania. The end user of the production line, the Tanzanian Ministry
of Defence, had previously sought to upgrade its existing production
capacities through the import of production equipment from Germany and
Belgium. The federal export authorities in both countries though denied
a license in 2000 and 2003 respectively. The export authorities of the
Walloon Region then received an essentially identical export license
application in 2004.
border-line case of Tanzania
export application can be seen to fall in the category of border-line
cases because of the mixed situation in Tanzania regarding national
arms control standards. On the one hand, Tanzania enjoys relative stability
in a volatile region and, as member to the Nairobi protocol on SALW,
is actively engaged in implementing a national action plan to combat
SALW proliferation. This includes legislative processes to amend national
laws and efforts to strengthen enforcement capacities. Further, the
Tanzanian Ministry of Defence submitted to the Walloon authorities an
end-use declaration that the produced ammunition would only be used
for domestic consumption. On the other hand, there are concerns regarding
the presently existing standards in Tanzania to prevent diversions from
production and stockpile sites and during transfers through theft, corrupt,
initially granting the license, the decision became public and was criticised
by, among other, the federal Belgian Ministry of Foreign Affairs, arms
control groups, and the media. In response, the Walloon authorities
suspended the license in March 2005 for three months to reconsider their
decisions. In particular, they sought to collate and evaluate new elements
to adequately assess the risk of diversion of ammunition to be produced
in Tanzania and the potentially destabilising effects in Tanzania and
neighbouring countries of such diversions.
delegation to clarify end-use condition
during that period by the Walloon authorities included the sending of
a governmental delegation to Tanzania to verify information on the ability
of the Tanzanian state to ensure responsible national management of
arms and ammunition. Through meetings with Tanzanian officials and arms
control experts as well as an on-site visit of the existing production,
the delegation could provide and clarify the conditions surrounding
the export application. The delegation concluded that if the export
were to be authorised, it would be of extreme pertinence to have strict
end-use conditions as well as a speedy finalisation and implementation
of Tanzania’s current overhaul of its arms control system.
a minimum, the delegation assisted the Walloon export authorities in
making a final decision on the basis of verified, detailed information
rather than only on the basis of the Tanzanian end-use declaration.
This, together with continued concerns voiced by the federal Belgian
Ministry of Foreign Affairs as well as by certain EU member states,
finally led the Walloon export authorities to withdraw and deny the
suspended license in June 2005.
1. The information presented in this box is based on research done by
GRIP, June 2005.
Strengthening post-export verification
It is further desirable
that EU member states exchange views and discuss experiences regarding their
efforts to verify compliance by end users in cases where end-use assurances
have been given. As mentioned, transfers of production capacities can entail
medium and long term risks for continued proliferation which are not necessarily
given in relation to exports of finite numbers of finished goods. EU member
states should therefore retain their right to demand that importers grant
access to production sites operating machines or technology originally exported
from the EU.
A useful model in this
context is found in the Bulgarian legislation on conventional arms exports.
This legislation stipulates that national authorities “may require from the
exporter the inclusion of a contractual provision allowing physical inspection
by them or by officials authorised by them of the delivery under the foreign
trade deal.”  Noteworthy in this context is also the USA.
It operates stringent post-export controls in relation to defence articles
particularly vulnerable to diversion or other misuse, or whose diversion or
other misuse could have significant consequences.  For example, US authorities annually cross-check information
held by them with data on stockpiled and employed MANPADS, including serial
numbers and quantities, which is regularly submitted by recipients of US exported
Sanctioning violations of end-use obligations
At the same time, EU
member states may face limits in their ability to undertake post-export controls.
The unsuccessful attempts by Belgian authorities to gain a clearer picture
of production levels at the Kenyan Eldoret facility that was furnished with
Belgian machinery are a case in point (see 2.2.1). EU member states should
therefore also deepen their discussions on common approaches if faced by alleged
or proven violations of end-use obligations.
Of interest here are
the automatic sanctions imposed in Germany on a recipient found to have violated
end-use obligations. That is, the German Political Guidelines for the
Export of Military Equipment stipulate that a recipient country which
violated or failed to prevent or sanction a violation it was aware of is considered
a non-desirable export destination. Export applications for military equipment
to the recipient country are therefore denied as a matter of principle until
such a time when the situation in the recipient country leading to the diversion
has been redressed. 
Conclusion and recommendations
As argued here, the
expected advances in EU export controls on production capacities under the
revised EU Code of Conduct are a welcome development but should be still further
developed. Moreover, strengthened standards are, with a view to the development
of high common export standards, highly desirable. In particular, it is recommended
that EU member states:
Complement the revised
EU Code with a common understanding that exports of production capacities
for military equipment will be conditional on strict end-use conditions.
The conditions should clearly stipulate that any re-transfer of production
capacities is either banned or only permissible with prior written consent
by the originally exporting state. Further, there should be clear stipulations
as to the end-use and end user of the goods derived from the production capacities,
as well as provisions allowing authorities of the originally exporting state
to request adequate post-export information. Violations of end-use assurances
or failure to provide access to production facilities or requested information
should entail a memorandum on exports of military equipment to the recipient
to assist national authorities in the implementation of the EU Code’s criterion
and operative provisions on preventing diversion risks. In particular,
a sub-group of the EU Council working group COARM should develop common understandings
on situations that would trigger a more detailed assessment of proliferation
risks at the licensing stage. Factors to be considered for such detailed assessments
should be detailed and provide national authorities with elements they should
check for during their decision-making.
 . Defence industry interviews, France, Belgium,
and Germany, April 2005.
 . Small Arms Survey (2002) Evaluating the human
costs. Geneva: Small Arms Survey, p.43ff.
 . Information held at GRIP.
 . Small Arms Survey (2001) Profiling the Problem.
Geneva: Small Arms Survey, p. 17.
 . Interview, German arms export official, Federal
ministry of Economics, Berlin, June 2004.
 . Amnesty International (2004) Undermining Global
Security: the European Union’s arms exports. AI, p.35f.
 . Communication with German Federal Criminal Police,
Bonn, January 2004.
 . Defence industry interviews, France, Belgium,
and Germany, April 2005.
 . See Biting the Bullet (2001) Stockpile Security
and Reducing Surplus Weapons. London: BASIC, Saferworld, International
 . Amnesty International (2004), p. 33ff.
 . Defence industry interviews, Belgium, April
 . Council of the European Union (1998) European
Union Code of Conduct on Arms Exports. EU Document 8675/2/98 REV 2.
Brussels: European Union (adopted on 8 June 1998), Criterion 7 a-c.
 . See Council of the European Union (2003), Fifth
Annual report according to operative provision 8 of the European Union Code
of Conduct on Arms Exports. EU Council document 14712/03. Brussels,
24 November, p.13.
 . Draft revised EU Code of Conduct on the
Export of Military Equipment. Operative provision 1b.
 . Ibid. Operative provision 4.
 . Ibid. Criterion 7.
 . OSCE (2000) OSCE Document on SALW. Vienna:
OSCE, Section III, A, 2b.vii and 2c.
 . Ibid. Section III, A, 3.
 . OSCE (2004) Principles for Export Controls
of Man-Portable Air Defence Systems (MANPADS). Vienna: OSCE, para. 2.1.
 . Ibid. paras. 2.5; and 2.6.
 . Defence industry interview, France, April 2005.
 . Politische Grundsätze der Bundesregierung
für den Export von Kriegswaffen und sonstigen Rüstungsgütern,
Berlin, 19 January 2000.
 . Politische Grundsätze der Bundesregierung.
Section III.1; and Section IV.2.
 . Bericht der Bundesregierung über ihre Exportpolitik
für konventionelle Rüstungsgüter im Jahre 2003
(Rüstungsexportbericht 2003), Berlin,
1 December 2004, p.17.
 . Defence industry interview, Germany, April
 . Bulgaria. Law on the Control of Foreign
Trade Activity in Arms and in Dual-Use Goods and Technologies, as amended
in 2002, art. 17.7.
 . United States (2003) Arms Export Control
Act, United States Code Title 22 – Foreign Relations and Intercourse, Chapter
39, as amended in 2003, section 2785.
 . US Department of Defense (2003) Security
Assistance Management Manual, DoD 5105.38-M, Chapter 8 – End-Use Monitoring
(EUM), October, point C22.214.171.124, p. 276.