Identifier
Created
Classification
Origin
07HONGKONG733
2007-03-15 05:12:00
UNCLASSIFIED
Consulate Hong Kong
Cable title:  

EXTRANCHECK: POST SHIPMENT VERIFICATION: ROHM AND HAAS

Tags:  BMGT BEXP HK ETRD ETTC 
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VZCZCXYZ0000
RR RUEHWEB

DE RUEHHK #0733 0740512
ZNR UUUUU ZZH
R 150512Z MAR 07
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 0917
RHMFIUU/HQ BICE WASHINGTON DC
UNCLAS HONG KONG 000733 

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: ROHM AND HAAS
ELECTRONIC MATERIALS

REF: A) USDOC 00994
UNCLAS HONG KONG 000733

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: ROHM AND HAAS
ELECTRONIC MATERIALS

REF: A) USDOC 00994

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 Rohm and Haas Electronic Materials
Asia Limited (Rohm & Haas),15 On Lok Mun Street, New Territories,
Hong Kong. The items in question are 31 drums of EBR-10A Edge Bead
Remover valued at USD 12,666. No export control classification
number (ECCN) was included on the relevant shipping documents
although related documentation provided by OEA states that the items
are classified as EAR99 (subject to the Export Administration
Regulations but not separately listed on the Commerce Control List).
Items properly classified as EAR99 may be exported/reexported to
virtually all destinations and end-users worldwide, license free.
The exporter is Rohm and Haas Electronic Materials LLC of
Marlborough, Massachusetts.


3. According to the Hong Kong Companies Registry, Rohm and Haas has
been in existence since 1979 (originally incorporated as Lea-Ronal
(S.E. Asia) Limited. A review of the relevant website
(www.electronicmaterials.rohmhaas.com) indicates that the company is
an affiliate of Rohm and Haas Electronic Materials LLC in
Marlborough, Massachusetts (the exporter). The Hong Kong Rohm and
Haas affiliateQs main business is importation and exportation of
electroplating chemicals for PCB boards, resistors and other
electronic components.


4. The ECO, accompanied by Commercial Assistant, Sandy Lai visited
Rohm and Haas at the address referenced above on March 7, 2007 and
met with Grace S.K. Cheung, Trade Compliance Specialist, Asia
Pacific. She provided background on Rohm and Haas and its business
as well as its worldwide and Hong Kong specific compliance program.



5. Ms. Cheung provided a spreadsheet of the various customers for
the applicable chemicals. She was not able to provide documentation
on the specific customers that received the particular shipment in
question because the chemicals were ordered for stock and delivered
to customers as they purchased them. Customers listed on the
spreadsheet provided by Ms. Cheung included CR Semiconductor, CSMC
Technologies, Daily Silver Imp Micrelectron, Hunan Puzhao
Information, RCL Semiconductor, Ltd., Shanghai Epic Music
Entertainment, Shanghai SIM-BCD Semiconductor, Shijaizhuang Concord
Electronics, Tianjin Zhonghuan Semiconductor, and Wuxi Zhongwei
Microchips Co.


6. Ms. Cheung is quite familiar with U.S. and Hong Kong export
controls (as her title would suggest). She had met the ECO at the
recent BIS/MOFCOM seminar on export controls. She stressed that
Rohm and Haas has a strong worldwide export compliance program that
makes use of SAP and Global Trade Solutions software. She stated
that she is part of the companyQs global compliance network and her
regional supervisor is located in Singapore.


7. At the time visited, Rohm and Haas appeared to be a suitable
recipient of the chemicals in question since Rohm and Haas
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 Rohm and Haas or put into
stock. 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