Written evidence submitted by ADS following oral evidence on 12 January

  1. ABOUT ADS

 

1.1  ADS is the premier trade association for the UK’s defence, security, aerospace, and space sectors. ADS has more than 1,100 member companies across all four sectors, with over 95% of these companies identified as Small and Medium Size Enterprises (SMEs). The UK is a world leader in the supply of aerospace, defence, security and space products and services. From technology and exports, to apprenticeships and investment, our sectors are vital to the UK’s growth, with companies in 2019 generating £79 billion turnover in the UK, including £46 billion in exports, and supporting over one million jobs.

 

1.2  ADS Chief Executive Paul Everitt provided oral evidence before the Committee on 12 January. There were a few areas covered which ADS is pleased to provide further evidence on.

 

  1. ACTION ON LICENSING IN RESPONSE TO A CHANGE IN CIRCUMSTANCES

 

2.1  When a situation changes in a customer nation, the Exports Control Joint Unit (ECJU) systematically examines all outstanding licences which have not yet been exhausted and, if deemed necessary, these are withdrawn or cancelled and the exporters in question are notified. This is also true of Open General Export Licences (OGELs). This is a longstanding practice by the ECJU.

 

2.2  Standard best practice, which ADS supports and disseminates, is that if a company has exported to an overseas customer and has since become aware that the customer intends on using the items for other purposes, they should notify ECJU in writing. This enables the Government to act should they be concerned about this proposed change in end-use.

 

  1. CROWD CONTROL APPARATUS EXPORTS

 

3.1  Under ECJU’s ‘OGEL Checker’, the types of crowd control equipment mentioned at the evidence session (i.e. tear gas, rubber bullets etc.) are not normally covered by OGELs because they require greater oversight.

 

3.2  There is some OGEL coverage, but not for permanent shipment to overseas customers. These include Export After Repair/replacement Under Warranty: Military Goods; Export For Exhibition: Military Goods; Exports or transfers in Support of UK Government Defence Contracts; Historic Military Goods; Military and Dual-Use Goods: UK Forces deployed in non-embargoed destinations.

 

3.3  Some Open Individual Export or Trade Control Licences have been issued, but this will have been after very careful and detailed consideration by Government.

 

  1. IMPACT OF BREXIT AND NORTHERN IRELAND

 

4.1  With relation to the Northern Ireland Protocol, Committee members referred to “arms export controls”, but Military List items are unaffected by the UK leaving the EU. ADS understands that the only impact is on dual-use items.

 

4.2  Components will be subject to export controls and detailed consideration of license applications against the Consolidated Criteria, if the components involved are deemed to be licensable.

 

  1. TRAINING AND AWARENESS

 

5.1  The Export Group for Aerospace, Defence and Dual Use (EGADD) has established a dedicated Training Sub-Committee which runs training events which complement those of the ECJU. EGADD has also established an Awareness Outreach Activities Sub-Committee to provide the ECJU with guidance on how best and most efficiently it can deploy its resources to maximise its effectiveness.

 

5.2  EGADD also provides speakers at some of the ECJU’s own events, as well as those organised by the UK Defence Solutions Centre. EGADD has created a three-day US Export Controls Workshops which have been run on an annual basis since April 2007, given the importance of US export controls for UK firms.

 

5.3  EGADD has also provided on-site training for individual companies on both US and UK export controls. Similarly, EGADD and Cranfield University have created a series of externally accredited training courses for different levels of audience.

14 January 2021