EXTRANCHECK: POST SHIPMENT VERIFICATION:

UNCLAS HONG KONG 000913

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:
TEGENT TECHNOLOGY LTD.

REF: A) USDOC 02348

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
Tegent Technology Ltd. (Tegent),Room 2103-05,
Westin Center, 26 Hung To Rd., Kwun Tong, Hong
Kong. The items in question are a gas
chromatograph and an electrical mass spectrometer
exported to Tegent on or about December 18, 2006
with a combined value of approximately USD 30,000.
On the applicable shippers export declaration
(SED),these items are classified as 3A999. Items
properly classified as 3A999 may be
exported/reexported license free to virtually all
destinations and end-users worldwide, except
certain terrorist sponsoring countries (including,
in particular, North Korea). The exporter was
Agilent Technologies of New Castle, Delaware
(Agilent).


3. According to the Hong Kong Companies Registry,
Tegent has been in existence since 1993. It has
registered share capital of HKD one million
(approximately USD 125,000). Directors are Hong
Kong identity card holders Hon Ching Cheung, Yan
Chiu Yu and Yan Oi Yu. According to Tegent's web
site (www.tegent.com.hk),the company is a leading
provider of high technology testing instruments to
customers in mainland China. Tegent lists typical
customers as laboratories involved in
environmental monitoring, food analysis, R&D and
petroleum product testing.


4. The ECO and Commercial Assistant Sandy Lai
visited Tegent at the address referenced above on
March 27, 2007 and met with Mr. Andrew Cheung,
General Manager. Mr. Cheung provided background
on Tegent. Consistent with the information noted
above, Mr. Cheung stated that Tegent has been in
business since approximately 1993. It sells
primarily U.S. and European-made instruments to
the Hong Kong and mainland China markets with
approximately USD 30 million in annual turnover.
It has approximately 150 staff in Hong Kong and
mainland China. Agilent is a major supplier to
Tegent of lab instruments and chemical analysis
machines. According to Mr. Cheung, typical uses
for these instruments include testing for
pesticide and antibiotics residue in foodstuffs as
well as pollution testing.


5. Mr. Cheung was familiar with export controls
noting that his company encounters the export
control requirements of the United States, Hong
Kong and Japan (for certain Agilent products
sourced from Japan). As to U.S. export controls,
Mr. Cheung stated that he relies primarily on
Agilent to take care of these formalities as it is
quite familiar with U.S. export control rules.
The ECO provided Mr. Cheung with information on
U.S. reexport controls (BIS publication 'Guidance
on the Department of Commerce's Reexport
Controls').


6. With respect to the shipment that was the
subject of the PSV, Mr. Cheung provided an
original purchase order reflecting that the items
were sold to Yunnan Tea Garden Group of Kunming,
China. Mr. Cheung stated that the items had not
yet been shipped to the customer and were
available for ECO's inspection in the company's
warehouse in the same building. Mr. Cheung
subsequently corrected himself and stated that the
items were located at another location awaiting
shipment. He offered to have them delivered from
the offsite location to the company for
inspection. On March 29, 2007, ECO and Commercial
Assistant Lai visited Tegent and were able to
inspect Agilent shipping boxes with the units


inside.


7. At the time visited, Tegent appeared to be a
suitable recipient of the commodities shipped (as
reseller) since Tegent cooperated with the PSV and
provided all requested information concerning the
final disposition of the applicable items. The
ECO recommends that this PSV be classified as
Favorable.
Cunningham