BLUE LANTERN LEVEL 3: POST-SHIPMENT END-USE CHECK

UNCLAS STATE 080984 SENSITIVE SIPDIS AIT TAIPEI FOR MATTHEW O'CONNOR ECON AIT TAIPEI FOR MI-YONG KIM AIT TAIPEI FOR REBECCA HESTER SINGAPORE FOR ELIZABETH CROSSON ECON E.O. 12958: N/A TAGS: ETTC KOMC SN TW SUBJECT: BLUE LANTERN LEVEL 3: POST-SHIPMENT END-USE CHECK ON LICENSES 050068901, 050071121, 050081551, AND 050082501 REF: A. SINGAPORE 427 ¶B. BLUE LANTERN GUIDEBOOK 2006 ¶1. (U) This is an Action Request. See paragraphs 2-5. ¶2. (U) The Department's Office of Defense Trade Controls Compliance (PM/DTCC) requests post's assistance in conducting a post-shipment check on licenses 050068901, 050071121, 050081551, and 050082501 for the export of zinc selenide to Taiwan. AIT Taipei and Embassy Singapore are requested to complete this Blue Lantern check within 45 days. Lack of response to a Blue Lantern check will affect pending and future licenses involving parties to this license. ¶3. (SBU) Reason for request: follow-on check due to previous unfavorable Blue Lantern check on application 050093417, which found that foreign consignee Wavelength Technology Singapore Pte. Ltd. sends all raw materials it receives to its facility in China for manufacturing (ref A). China is a proscribed destination for United States Munitions List (USML) commodities, such as the ones exported under subject licenses, under Section 126.1 of the U.S. International Traffic in Arms Regulations (ITAR). Wavelength is on PM/DTCC's Watch List. AIT Taipei and Embassy Singapore should make appropriate inquiries to determine if foreign end-user Legend Laser in Taiwan has received the zinc selenide listed on these licenses or if Legend Laser received components manufactured using the zinc selenide. AIT Taipei and Embassy Singapore should also determine if the zinc selenide was re-exported to China for manufacturing, and if so, what manufacturing processes were employed. Department requests that AIT Taipei conduct a site visit to Legend Laser in order to provide Department with an assessment of its business operations and on-site security. If a site visit is not possible, please inform PM/DTCC case officer. Since Embassy Singapore has already conducted a site visit to Wavelength Technology, Department defers to post's judgment on the need or desirability of one in connection with this check. The following questions are offered as guidance for AIT Taipei and Embassy Singapore. ¶4. (U) Questions for AIT Taipei to ask Legend Laser: --Did the company receive from Wavelength Technology all of the zinc selenide listed on these four licenses? Or did the firm instead receive from Wavelength Technology finished or partially finished components that were manufactured using the zinc selenide? --Did the company receive the units of zinc selenide? Or did the company receive components containing zinc selenide that were manufactured by Wavelength Technology? If so, were the components shipped to the company from Wavelength Technology's facilities in Singapore or its facilities in China? --Did Legend Laser order from Wavelength Technology the exact type and quantity of items listed on this application? Did Legend Laser order anything else from Wavelength, either currently or in the past? --What did Legend Laser do with the materials or devices that it received from Wavelength? If Legend Laser stored the items listed on the application, does it have secure facilities and proper accounting and security procedures for handling these sensitive USML items? --When was the company established and who are its principals? --What is the nature of its business -- what types of items does it handle, does it serve as a broker? --What types of organizations are among its typical customers and where are the customers located? Are any of its customers located in China? --Does the company understand the restrictions on United States Munitions List (USML) items, especially the prohibition against unauthorized re-transfers and re-exports? ¶5. (U) Questions for Embassy Singapore to ask Wavelength Technology: --Was the zinc selenide listed on these four licenses re-exported to one or both of the company's facilities in China for manufacturing? --Who exactly in China manufactured or modified the materials? (COMMENT: If possible, please obtain exact contact information, including names, addresses, phone numbers, fax numbers, and e-mail addresses. END COMMENT.) --Are all materials that the company sends to China returned to Wavelength's office in Singapore? Or are some sent directly to other customers in China and other countries? If so, what other countries and what other firms? --What other customers in China does Wavelength Technology have? --Is Wavelength Technology involved in any joint business partnerships or ventures with other businesses, especially in China? --What is the use for the zinc selenide (ZnSe) devices? Light emitting diodes or diode lasers? --During the manufacturing process, are the devices doped with chromium (ZnSe:Cr) or tellurium (ZnSe:Te)? --Does the company understand the restrictions on United States Munitions List (USML) items, especially the prohibition against unauthorized re-transfers and re-exports? Does the company understand that China is a proscribed destination for USML items under U.S. laws and regulations? END ACTION. ¶6. (SBU) For background, the following details of the application in question are provided: ¶A. DDTC Case: 050068901 QUANTITY/COMMODITY: 15 Zinc Selenide (ZnSe) sufficient material to yield 179 mm diameter x 14 mm thick (lenses) License Value: USD 78,105.00 (COMMENT: Ten of the 15 ZnSe units were exported to Singapore on 11/30/2007. No further units have been exported. END COMMENT.) SELLER: Rohm and Haas Company CVD Incorporated dba Advanced Materials 185 New Boston Street Woburn, MA 01801 Company contact: Jeff Hobart, tel. 781-933-9243 FOREIGN CONSIGNEE: Wavelength Technology Singapore Pte Ltd Blk 2 Bukit Batok St 24, #06-03 Skytech Bldg, 659480 Singapore Tel: 65-6564 9624 Fax: 65-6564 3862 E-mail: info@wavelength-tech.com Co. Business No. 200206988D FOREIGN END-USER: Legend Laser Inc. 8F-11, No. 3 Wucheng Rd. Shin-Chuang Taipei Hsien 248 Taiwan PURPOSE: This ZnSe material will be used to construct scan lenses for CO2 laser systems. This is a commercial (non-military) application. The material is controlled due to its diameter exceeding 5 inches per commodity jurisdiction DDTC case DJ 060-07. ¶B. DDTC Case: 050071121 QUANTITY/COMMODITY: 6 Zinc Selenide (ZnSe) sufficient material to yield 124.5 mm diameter x 14.5 mm thick (lenses) License Value: USD 16,620.00 (COMMENT: All six ZnSe units were exported to Singapore on 11/30/2007. END COMMENT.) SELLER: Rohm and Haas Company CVD Incorporated dba Advanced Materials 185 New Boston Street Woburn, MA 01801 Company contact: Jeff Hobart, tel. 781-933-9243 FOREIGN INTERMEDIATE CONSIGNEE: Rohm and Haas EM, K.K. Sanbancho UF Bldg Chiyodo-Ku, 6-3 Sanbancho Tokyo 102-0075 Japan Asia sales office of applicant FOREIGN CONSIGNEE: Wavelength Technology Singapore Pte Ltd Blk 2 Bukit Batok St 24, #06-03 Skytech Bldg, 659480 Singapore Tel: 65-6564 9624 Fax: 65-6564 3862 E-mail: info@wavelength-tech.com Co. Business No. 200206988D FOREIGN END-USER: Legend Laser Inc. 8F-11, No. 3 Wucheng Rd. Shin-Chuang Taipei Hsien 248 Taiwan PURPOSE: This ZnSe material will be used to construct scan lenses for CO2 laser systems. This is a commercial (non-military) application. The material is controlled due to its diameter exceeding 5 inches per commodity jurisdiction DDTC case DJ 060-07. ¶C. DDTC Case: 050081551 QUANTITY/COMMODITY: 30 Zinc Selenide (ZnSe) sufficient material to yield 179 mm diameter x 14 mm thick (lenses) 5 Zinc Selenide (ZnSe) sufficient material to yield 125.5 mm diameter x 14.5 mm thick (lenses) License Value: USD 161,750.00 (COMMENT: A total of 32 ZnSe units were exported to Singapore in three shipments on 1/17/2008, 1/24/2008, and 3/1/2008, respectively. No further units have been exported. END COMMENT.) SELLER: Rohm and Haas Company CVD Incorporated dba Advanced Materials 185 New Boston Street Woburn, MA 01801 Company contact: Jeff Hobart, tel. 781-933-9243 FOREIGN INTERMEDIATE CONSIGNEE: Rohm and Haas EM, K.K. Sanbancho UF Bldg Chiyodo-Ku, 6-3 Sanbancho Tokyo 102-0075 Japan Asia sales office of applicant FOREIGN CONSIGNEE: Wavelength Technology Singapore Pte Ltd Blk 2 Bukit Batok St 24, #06-03 Skytech Bldg, 659480 Singapore Tel: 65-6564 9624 Fax: 65-6564 3862 E-mail: info@wavelength-tech.com Co. Business No. 200206988D FOREIGN END-USER: Legend Laser Inc. 8F-11, No. 3 Wucheng Rd. Shin-Chuang Taipei Hsien 248 Taiwan PURPOSE: This ZnSe material will be used to construct scan lenses for CO2 laser systems. This is a commercial (non-military) application. The material is controlled due to its diameter exceeding 5 inches per commodity jurisdiction DDTC case DJ 060-07. ¶D. DDTC Case: 050082501 QUANTITY/COMMODITY: 3 Cleartran(TM) Zinc Sulfide (ZnS) sufficient material to yield 212 mm diameter x 149 mm x 14 mm thick (lenses) License Value: USD 13,080.00 (COMMENT: All three ZnSe units were exported to Singapore on 3/28/2008. END COMMENT.) SELLER: Rohm and Haas Company CVD Incorporated dba Advanced Materials 185 New Boston Street Woburn, MA 01801 Company contact: Jeff Hobart, tel. 781-933-9243 FOREIGN INTERMEDIATE CONSIGNEE: Rohm and Haas EM, K.K. Sanbancho UF Bldg Chiyodo-Ku, 6-3 Sanbancho Tokyo 102-0075 Japan Asia sales office of applicant FOREIGN CONSIGNEE: Wavelength Technology Singapore Pte Ltd Blk 2 Bukit Batok St 24, #06-03 Skytech Bldg, 659480 Singapore Tel: 65-6564 9624 Fax: 65-6564 3862 E-mail: info@wavelength-tech.com Co. Business No. 200206988D FOREIGN END-USER: Legend Laser Inc. 8F-11, No. 3 Wucheng 1 Rd. Shin Chuang Taipei Hsien 248 Taiwan PURPOSE: This Cleartran(TM) multi-spectral ZnS material will be used to construct scan lenses for CO2 laser systems. This is a commercial (non-military) application. The material is controlled due to its diameter exceeding 5 inches per commodity jurisdiction DDTC case CJ 060-07A. ¶7. (U) Submitted in support of the license application were the following documents (PM/DTCC can fax documentation to post upon request): ¶A. --End-User/End-Use Statement from Wavelength Technology, signed by Jenny Zhu, Director, dated 13/09/07 --Purchase order no. PO-1927 from Wavelength Technology to Rohm and Haas, Advanced Materials, unsigned, dated 23/07/07 --Product brochure, including technical specifications ¶B. --End-User/End-Use Statement from Wavelength Technology, signed by Jenny Zhu, Director, dated 06/09/07 --Purchase order no. PO-2108 from Wavelength Technology to Rohm and Haas, Advanced Materials, unsigned, 07/09/07 --Product brochure, including technical specifications ¶C. --End-User/End-Use Statement from Wavelength Technology, signed by Jenny Zhu, Director, dated 27/12/07 --Purchase order no. PO-2462 from Wavelength Technology to Rohm and Haas, Advanced Materials, unsigned, 24/12/07 --Product brochure, including technical specifications ¶D. --End-User/End-Use Statement from Wavelength Technology, signed by Jenny Zhu, Director, dated 04/01/08 --Purchase order no. PO-2467 from Wavelength Technology to Rohm and Haas, Advanced Materials, unsigned, 28/12/07 --Product brochure, including technical specifications ¶8. (U) Please slug reply for PM/DTCC - BLUE LANTERN COORDINATOR and include the words "Blue Lantern" and the case number in the subject line. POC is Judd Stitziel, PM/DTCC, Phone: 202-663-3455; email: StitzielJD@state.gov; SIPRNET: StitzielJD@state.sgov.gov. The Blue Lantern Guidebook (ref B) is available as a PDF file in the Bunche Library's Electronic Library collection on the DOS Intranet: http://virtuallibrary.state.gov/ BlueLanternGuidebook2006%2520 final .pdf ¶9. (U) The Department appreciates post's assistance in this matter. RICE