Annual Report on Export and Import of Military Goods and ... - SIPRI

ANNUAL REPORT ON EXPORT AND IMPORT OF MILITARY GOODS AND NON-MILITARY LETHAL GOODS IN 2009
6.
Licenses issued in
2009
Table 3. Analysis of export and import licenses issued per category
List of military goods
List of non-military
lethal goods
Temporary export /
import
General license
Export 113 44 22 75
Import 143 305 2 /
22
The Ministry issued 75 general licenses for the export of
military helmets and accompanying equipment, belonging
to the category ML13 of the List of Military Goods, for
the purpose of presentation at fairs and tenders.
On the basis of the Commission’s opinion, the Ministry
rejected the total of 48 requests for export, import and
the provision of services. The requests were mostly rejected
because of the fact that companies did not fulfill the
conditions prescribed by Law, or because they were not
registered in the relevant registers; there were also several
cases in which the companies were unable to deliver all
the prescribed documentation.
Chart 2 contains the overview of licenses for the export
of military goods per country. It is obvious from the chart
that the biggest portion of the total of 113 issued licenses
pertains to the United States of America (30 licenses).
Given the fact that the licenses are issued with a validity
period of up to 6 months, a considerable number of approved
licenses remain unused, or used only partially. On
the basis of the analysis that was undertaken, it was noted
that the biggest volume of requested and unused export
licenses pertains to the export of Croatian pistols and
their parts to the US, because of the fact that the Croatian
exporter is adjusting his export request to the quantities
specified in the US license.
In addition, it is important to point out that the tables attached
do not show the data on used licenses, despite the
fact that the exporters and importers have the duty, stipulated
in Article 26 of the Law, to inform the Ministry in
writing of the performed export or import upon its completion,
and to attach the documentation on the basis of
which this export or import was performed.
In order to gain a better overview of the performed export
and import of the relevant goods, the Ministry of
Economy, Labor and Entrepreneurship requested from
the Ministry of Finance – the Customs Administration
to provide data on the usage of licenses issued in 2009.
However, the insight into data received from the Customs
Administration has shown that this data was not derived
from the licenses issued by the Ministry of Economy, Labor
and Entrepreneurship, which made it impossible to
determine whether these goods belong to the goods
listed in the List of Military Goods, or to those from the
List of Non-Military Lethal Goods. Namely, the report of
the Customs Administration does not say which license
constituted the basis for a particular case of export or import,
nor is there data on the number of the license issued
by the Ministry of Economy, Labor and Entrepreneurship.
Therefore, it was impossible to create a comparative
overview of the Customs Administration report and the
reports delivered by exporters or importers. However,
in individual cases, where the creation of a comparative
overview was possible, it turned out that the data delivered
by the exporters and importers does not correspond
in full to the data from the <strong>Report</strong> of the Customs Administration.
To be exact, the measurement unit used in the
licenses of the Ministry approving the export or import of
arms, parts of arms, ammunition and military equipment
is “unit of goods”, while the <strong>Report</strong> of the Customs Administration
used “kilograms of goods” as the measurement
unit in several cases.
Given the fact that the data delivered by the Customs
Administration was not fully comparable with the data
delivered by the exporters or importers, this data was
not introduced into the <strong>Annual</strong> <strong>Report</strong> of the Ministry of
Economy, Labor and Entrepreneurship for 2009.
However, it is important to emphasize that, as of January
1, 2010, the Customs Administration began processing
the licenses through the TRACKER Program, which is used
by this Ministry for the issuance of licenses. Namely, this
Program enables precise and high-quality analysis per license
type, taking into account factors such as whether a
license is issued for export or import of military and nonmilitary
lethal goods, for the provision of services for military
goods, or for export of dual-use goods.