EXTRANCHECK: POST SHIPMENT VERIFICATION: A&P

UNCLAS HONG KONG 000150

SIPDIS

USDOC FOR 532/OEA/LHINES/DFARROW
USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR WILLIAM
ZARIT
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS

SIPDIS

E.O. 12958: N/A
TAGS: BMGT BEXP HK ETRD ETTC
SUBJECT: EXTRANCHECK: POST SHIPMENT VERIFICATION: A&P
INSTRUMENT CO LTD

REF: A) USDOC 06875 B) D362961

1.Unauthorized disclosure of the information provided
below is prohibited by Section 12C of the Export
Administration Act.


2. As per reftel A request and at the direction of the
Office of Enforcement Analysis (OEA) of the USDOC
Bureau of Industry and Security (BIS),Export Control
Officer Philip Ankel (ECO),accompanied by Commercial
Assistant Sandy Lai, conducted a post shipment
verification (PSV) at A&P Instrument Co. Ltd. (A&P),
Unit 1, Kam Hon Industrial Building, 8 Wang Kwun Road,
Kowloon Bay, Hong Kong. The items in question are two
position elliptical valves exported to A&P on October
27, 2006 and valued at USD 158. The Export Control
Classification Number (ECCN) is 2B350 and the items
were exported pursuant to export license D362961. The
exporter was Cole-Parmer Instrument Company of Vernon
Hills, Illinois.


3. The ECO visited A&P at the address referenced above
on January 9, 2007 and met with Mr. Andy Wu, Senior
Manager. Mr. Wu provided background on A&P and its
business, which involves the resale and distribution of
testing equipment and other scientific instrumentation
(more information including names of various U.S.
suppliers at www.anpico.com). Mr. Wu stated that the
company had been representative of the exporter, Cole-
Parmer, for 24 years. He noted that A&P initially
focused primarily on customers in Hong Kong but with
the transition of significant manufacturing to the
mainland, presently A&P's main business is with
mainland Chinese companies (multiple mainland China
offices are noted in the A&P website).


4. A review of the Hong Kong Companies Registry reveals
that A&P has been in business since 1990 and that Mr.
Wu, a Hong Kong resident, is a director as is Hong Kong
resident Yuet Ling Au.


5. With respect to the shipment that was the subject
of the PSV, Mr. Wu provided the applicable
documentation reflecting that the items had been
received by A&P and subsequently resold to the end-user
noted on license D362961, namely Millipore China
Limited (Millipore). The U.S. parent of Millipore
China Limited (Millipore Corporation) is a New York
Stock Exchange listed company that provides a range of
products and services in the biopharmaceutical
manufacturing and medical research fields
(www.millipore.com). Mr. Wu stated that at the request
of Cole-Parmer, he obtained from Millipore a statement
regarding the proposed end-use of the items, a copy of
which he provided to the ECO. That statement was in
the form of an e-mail indicating that the items were
for "valve use for filtration system." Mr. Wu stated
that the item was for use in Hong Kong and was
delivered to Millipore in Hong Kong. Mr. Wu also
stated that he was made aware of the conditions of
License D362961 and provided ECO with a copy of the
license itself.


6. Mr. Wu also stated that he is familiar with both
U.S. and Hong Kong export licensing rules. He further
stated that as a general rule A&P avoids dealing in
items that may require an export license as obtaining
such licenses represents a significant regulatory
burden. He noted that A&P's items typically are not at
the level of technical sophistication that would result
in them being controlled for export. Information
provided by OEA to the ECO indicates that A&P has
rarely been the subject or applicant in export/reexport
licenses.


7. At the time visited, A&P appeared to be a suitable
recipient of the commodities shipped since A&P
cooperated with the PSV and provided all requested
information concerning the use and final disposition of
the shipment. At the same time, the ECO was not able
to inspect the subject item as it had already been
delivered to A&P's customer, Millipore. Consistent
with guidance on reporting of PSVs where the items
cannot be physically inspected, the ECO recommends that
this PSV be classified as Limited.