EXTRANCHECK: POST-SHIPMENT VERIFICATION: SARTORIUS INDIA

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



2. Acting Export Control Officer (ECO) David Nardella and BIS FSN
Prem Narayan conducted a Post-shipment Verification (PSV) at
Sartorius India Pvt. Ltd. (Sartorius), Bangalore, on January 23,


2007.



3. BIS requested a PSV at Sartorius, a private sector company,
located at: #10, 3rd Phase Peenya, 6th Main, KIADB Industrial Area,
Bangalore 560058, Tel: 91-80-2837-7728, Fax: 91-80-4117-1840,
Email:
amit.chatterjee@sartorius.com, Website: www.sartorius.com. The PSV
was requested under EAR99/NLR. Sartorius was listed as Ultimate
Consignee for five transactions for pumps and pump parts. The
exporter was Barnant Company, Barrington, Illinois.



4. ECO along with FSN Narayan met with Amit Chatterjee
(Chatterjee),
Managing Director, Biju Joseph (Joseph), Vice
President-Manufacturing and N. Ramesh (Ramesh), Assistant
Manager-Materials, Sartorius.



5. BIS requested seven (7) PSVs to be conducted at Sartorius for
different commodities imported from seven different U.S. firms,
including its U.S. affiliation Sartorius North America. Chatterjee
and his colleagues were not aware of the BIS regulations. This was
the first official visit by a USG or BIS official to Sartorius.
Chatterjee stated that they regularly import products from U.S.
companies. He stated that in the absence of the U.S. exporters'
invoice numbers or relevant transaction papers, it will be
difficult
to locate the relevant transaction documentation. BIS team did not
possess invoices for any of the 7 requested PSVs.



6. ECO then advised Chatterjee that BIS, through its headquarters,
will obtain the copies of invoices and forward to Sartorius. ECO
asked Chatterjee if he would permit the PSV to commence, once all
associated invoices are obtained and provided to him. Chatterjee
reluctantly replied that he believed the checks would be allowed,
but added he would need to inquire with the parent company, to
determine if there are corporate legal concerns associated with the
PSVs.



7. He asked the BIS Team to first obtain, and forward to him the
transaction invoices. He would then seek approval from his parent
company in Germany, for the PSVs to commence. Chatterjee noted
that
the subject equipment might not be at their facility because much
of
what Sartorius purchases is integrated into custom products sold to
customers.



8. The invoices for the Barnant Company exports were obtained and
forwarded to Sartorius on March 5, 2007. Based on the information
in the invoices, Sartorius reported the Barnant pumps and pump parts
were incorporated into filtration systems which were sold to three
separate end users in Hyderabad. The end users are: Nagarjuna
Fertilizers & Chemicals, Gokaraju and Rengaraju Institute of
Engineering & Technology and Abdul Quadir Jeelari Center for Post
Graduate Studies.



9. Sartorius was established in 1992, is a fully owned subsidiary
of
Sartorius AG based in Goettingen, Germany. According to company
brochure Sartorius is one of the leading laboratory and process
technology providers covering the segments of biotechnology and
mechatronics. For biotechnology industry Sartorius manufactures
membrane filters, syringe filters, vacuum filtration units,
pressure
filtration units and venting units. In mechatronics it
manufactures
analytical balances, precision balances, micro and ultra
micro-balances, moisture analysis equipment, and electrochemical
analysis equipment. In addition, it manufactures gold and carat
weighing scales. The key Sartorius customers include
pharmaceutical, chemical and food and beverage industries. In
addition, it sells its products to several research and educational
institutes of the public sector undertakings (PSU). In India
Sartorius is headquartered in Bangalore along with two
manufacturing
facilities with five regional offices located in Mumbai, New Delhi,
Kolkata, Secunderabad, and Chennai. Sartorius sales in FY 2006

were
approximately $23 million. It employs 450 personnel India-wide.



10. Recommendation: While all indications are that the commodity is
being used by Sartorius in its manufacturing process in accordance
with the Export Administration Regulations the ECO will be unable to
physically verify their actual end use. As such this check is
inconclusive. (PDAVIS/PNARAYAN) Pyatt