EXTRANCHECK: POST SHIPMENT VERIFICATION:

UNCLAS HONG KONG 000429

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:
VICKERS SYSTEMS LTD
REF: A) USDOC 06874

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) and Assistant Director for
Operations, John Sonderman, conducted a post shipment
verification (PSV) at Vickers Systems Ltd., Units 18-
30, 19F Corporation Park, 11 On Lai St. Shatin, Hong
Kong (Vickers). The items in question are 246
hydraulic valves valued at USD 7,307. No export
control classification number (ECCN) was included on
the relevant shipping documents. The exporter is
Eaton Corporation of Pharr, Texas.


3. According to the Hong Kong Companies Registry,
Vickers Systems Limited has been in existence since

1983. A review of the relevant website
(www.eaton.com) indicates that the company is an
affiliate of Eaton Corporation (the exporter). Its
business is importation and exportation of various
hoses, pumps, valves and related items. It handles
various brands including Vickers, Orbit, Eaton,
Aeroquip and others.


3. The ECO and A/D Sonderman visited Vickers at the
address referenced above on January 19, 2007 and met
with Mr. T.T. Kuan, Business Manager and Mr. Lawrence
Chiu, Distribution Centre Manager. They provided
background on Vickers and its business, which
involves the distribution of Eaton and other brand
hoses, hose fittings, hydraulic systems and related
components to Hong Kong, mainland China, Taiwan and
the region.


4. Ms. Chiu provided by attachment to separate e-
mail, shipping and order documentation accounting for
all 246 valves that are the subject of this PSV. The
six customers for these valves appear to be
industrial companies in Hong Kong and mainland China
(this is based on a web site review of the customer
names).


5. Messrs. Chiu and Kuan were only somewhat familiar
with U.S. export control regulations but stated that
the parent company (Eaton in the U.S.) assists
Vickers in this respect. The ECO provided background
information on reexport controls.


6. At the time visited, Vickers appeared to be a
suitable recipient of the valves since Vickers
cooperated with the PSV and provided all requested
information concerning the final disposition of the
items. At the same time, the ECO was not able to
inspect the subject items as they had already been
delivered to the customers of Vickers. Consistent
with guidance on reporting of PSVs where the items
cannot be physically inspected, the ECO recommends
that this PSV be classified as Limited.
Cunningham