China Nonproliferation Export Control System: Evolution and Revolution. Jishe Fan STPP/MTA Fellow Belfer Center/KSG

China Nonproliferation Export Control System: Evolution and Revolution Jishe Fan STPP/MTA Fellow Belfer Center/KSG

Outline 1, Evolution of China s nonproliferation export control system 2, China s export control process: a brief introduction 3, China s Export Control Achievements and Challenges 4, Conclusion and recommendations

1, Evolution of China s Export Control System Based on changes of China s administrative system, its legal framework, its relations with arms control and nonproliferation regimes, and China s export activities, the evolution of China s nonproliferation export control system could be divided into four stages 1949-1979 years of tight control, and limited export 1979-1992 Years of increased export, limited control 1993-2002 Moving toward De Jure Export Control 2002-2008 Years of Transformation

1.1 1949-1979 years of tight control, and limited export ---Administrative System Rebuild its economic and trade system Central Trade Ministry was set up 1952, China replaced the Central Trade Ministry with Ministry of Foreign Trade to take care of foreign trade, and its local branches were set up in all provinces. ---Legal Framework the Provisional Rules of Foreign Trade Administration ( 对 外 贸 易 管 理 暂 行 条 例 ) Detailed Rules Regarding the Provisional Rules of Foreign Trade Administration ( 对 外 贸 易 管 理 暂 行 条 例 实 施 细 则 )---December 1950, license requirement, not proliferation specific Socialist transformation of capitalist industry and commerce (1956) 15 state-owned big foreign trading companies (1957)

---China s Relations with arms control and nonproliferation regimes Non-involvement in any treaties Non-involvement in any multilateral export control regimes Coordinating Committee for Multilateral Export Control (COCOM), Zanger Committee, Nuclear Supplier Group (NSG), Embargoed by US, and at the receiving end of COCOM (China Committee, 1952) China would not comply with any treaty obligations which China did not participate in negotiation or sign (January 22, 1960, Chen Yi) China was very critical of these agreements, and showed no support, either rhetorically or in practice, of these treaties, especially those that might limit or constrain China s capability to develop nuclear weapons. Rhetorically supported proliferation of nuclear weapons, but China was very cautious in proliferation (October 17, 1965, Chen Yi)

---China s Strategic Trade No real proliferation (protocol with North Korea in 1959, agreements with Pakistan in 1966, LEU to Iraq in the 1970s) Some military assistance to third world countries. 1950 to 1963, Vietnam, North Korea, Algeria, Cuba, Laos, Guinea, Albania, Cambodia 1964 to 1978, more than 60 Asian and African countries requested and accepted Chinese military assistance. Vietnam ( 地 空 导 弹 系 统 3 套 和 180 枚 导 弹 ) and Albania received missile systems and missiles ( 地 空 导 弹 系 统 2 套 和 224 枚 导 弹 ). Ideology motivated, and free of charge ---Explanation of China s Policy China s foreign trade was put under tight control of the central government. China the defense industry was fully subsidized by the government China mainly argued for its own right in developing nuclear weapons China s domestic economic growth was much independent of world economy, and China s economy was much of self-sufficiency autarky. (9.8% dependence, 4.6% of GDP) China did not have much to proliferate at all at that time since China has a fairly poor science and technology bases.

---Legacy China s perception of arms control and nonproliferation was very negative China was the key target of export control regime (biased and discriminatory Western institution). China does not think it has any obligation to observe those rules in strategic trade China made a clear differentiation between nuclear weapons and the peaceful use of nuclear energy since 1954. China formed its basic principles in handling foreign relationship with other countries, namely, the five principles of peaceful co-existence. Non interference of internal affairs

1.2 1979-1992 Years of increased export, limited control ---Administrative System State Council and Central Military Commission authorized several ministries to set up different companies for foreign trade in February 1980 Name of Associated Ministry 国 防 工 办 National Defense Industrial Office Name Of Company 中 国 新 时 代 公 司 China New Era Company 国 防 科 委 National Defense Science and Technology Commission 中 国 燕 山 科 学 技 术 公 司 China Yanshan Science and Technology Company 二 机 部 核 The Second Ministry of Machine Building Industry 中 国 原 子 能 工 业 公 司 China Nuclear Energy Industry Corporation (CNEIC) 三 机 部 航 空 The Third Ministry of Machine Building Industry 中 国 航 空 技 术 进 出 口 公 司 China National Aero-Technology Import & Export Company 四 机 部 电 子 The Fourth Ministry of Machine Building Industry 中 国 电 子 技 术 进 出 口 公 司 China National Electronics Import and Export Corporation 五 机 部 兵 器 工 业 The Fifth Ministry of Machine Building Industry 中 国 北 方 工 业 公 司 China North Industry Corporation (NORINCO) 六 机 部 潜 艇 The Sixth Ministry of Machine Building Industry 中 国 船 舶 工 业 公 司 China Shipbuilding Industrial Company 七 机 部 航 天 / 导 弹 The Seventh Ministry of Machine Building Industry 中 国 长 城 工 业 公 司 China Great Wall Industry Corporation (CGWIC) 八 机 部 卫 星 和 空 间 技 术 The Eighth Ministry of Machine Building Industry 中 国 精 密 机 械 进 出 口 公 司 China National Precision Machinery Import and Export Corporation (CPMIEC)

The reorganization in 1982 Second Ministry of Machine Building Industry----Ministry of Nuclear Industry Third Ministry of Machine Building Industry --- Ministry of Aviation Industry Fourth Ministry of Machine Building Industry --- Ministry of Electronics Industry Fifth Ministry of Machine Building Industry --- Ministry of Ordnance Industry Sixth Ministry of Machine Building Industry ---China Shipping Industrial Corporation Seventh and Eighth Ministry of Machine Building Industry---Ministry of Space Industry. The reorganization in 1988 Ministry of Nuclear Industry--- China National Nuclear Industry Corporation Ministry of Aviation Industry and Ministry of Space Industry ---Ministry of Aviation and Space Industry Ministry of Ordnance Industry --- China North Industry Corporation China Electronics Industry Corporation (CEIT) created in 1991 Commission of Science Technology, and Industry for National Defense (COSTIND, 1982) --PLA National Defense Science and Technology Commission, State Council s National Defense Industrial Office, and the Science, Technology, and Equipment Commission (STEC) of the CMC Nuclear, aviation, ordnance, and space under the jurisdiction of the State Council in July 1986 State Council and CMC Leading Group for Military Product Trade in September 26, 1989 (State Administrative Committee on Military Products Trade (SACMPT)) the administrative body for military transfer, Foreign Ministry, General Staff Department, COSTIND, Ministry of Foreign Trade, other department

---Legal Framework February 25, 1980, Some Temporary Provisions on National Defense Industry Import and Export( 国 防 工 业 部 门 开 展 进 出 口 工 作 若 干 暂 行 规 定 ) June 1980, Temporary Provisions of the Export Licensing System March 1985 circular to set up the division of labor between Ministry of Foreign Trade and its local branches in issuing license January 1989, the penalty provision on violation of licensing system with GAC The 1992 Temporary Provisions of Export Goods Management October 1986, Ministry of Foreign Trade and State Science and Technology Commission were designed as two executive bodies responsible for the review and approval of technology export. 1987, Temporary Rules on Encouraging Technology Export COSTIND was responsible for review and approval of conventional military export, while the contract of military technology export would be reviewed and approved by Ministry of Foreign Trade

The Two-Three principles governing nuclear and military trade the export of such weapons should help the recipient nation increase its appropriate defense capacity; the transfer must not impair peace, safety or stability regionally or globally; China does not use trade in weaponry to interfere in sovereign states' internal affairs exports serving peaceful use only, accepting IAEA's safeguards and no retransfers to a third country without China's consent.

---China s Relations with arms control and nonproliferation regimes China signed a number of arms control agreements and some protocols of NWFZ, Participating the arms control, and disarmament forums, and propose initiatives Join in IAEA in September 1983. Changing attitude toward NPT (1983, discriminatory treaty, 1987, agree with the principle, 1990, attend the 4 th NPT review conference, NPT s positive effect in nonproliferation, contribution to stability, support the three principles, prepared to join in NPT) We do not advocate or encourage nuclear proliferation. We do not engage in nuclear proliferation ourselves, nor do we help other countries develop nuclear weapons ---Zhao Ziyang, January 1984. Improvement of China s relationship with COCOM, and US China not involved in the negotiation of MTCR, and promised to adhere to Guidelines and Parameters

---China s Strategic Trade China sold natural uranium, LEU, HEU, Uranium hexafluoride, yellowcake, heavy water to many countries. China began to sign contracts to provide power reactors and research reactors (some were cancelled later) to some developing countries such as Algeria, Iran, and Syria Other nuclear cooperation covers uranium mining, training, dual use technology, ect. China-Algeria nuclear cooperation (February 1983) China-Iran nuclear cooperation In 1989 and 1991, China and Iran signed two commercial contracts, and China agreed to provide Iran electromagnetic isotope separators and a Miniature subcritical neutron source reactor In September 1992, China and Iran signed one more nuclear cooperation agreement, under which China would provide 20 MWt research reactor, two 300 MW pressurized water reactors

China and Pakistan nuclear cooperation early 1980s In 1986, comprehensive nuclear cooperation agreement In December 1991, contract to build a 300MW nuclear power reactor for Pakistan China missile exports to Iran: 1986-1987, China transferred HY-2 (Silkworm) and C-801 anti-ship cruise missiles to Iran 1989, China also sold around 150-200 M-7/8610 ballistic missiles to Iran. Discussion about the transfer of M-9 and M-11 in late 1980s and early 1990s.. China missile exports to Pakistan: China and Pakistan discussed the possible sale of M- 11 missile to Pakistan in late 1980s, and a contract was signed in 1988. in late 1992, there were reports that China had transferred 34 complete M-11 systems to Pakistan. China missile exports to Syria: China agreed to provide M-9 (DF-15) missiles to Syria in May 1991. China missile exports to Saudi Arabia: China provided 36 DF-3 (CSS-2) to Saudi Arabia in 1988

---Explanation of China s Policy Opening up and Reform policy has a serious, and negative impact on China s defense industry. China keeps a guarded attitude toward most arms control and disarmament treaties, organizations, and regimes China was trying to regulated its export control, but the decision making process was too complicated to be effective. The top priority after 1978 is to promote export rather than control export The need to earn foreign currency may have been the single most important factor motivating Chinese export of sensitive goods and technology

1.3 1993-2002 Moving toward De Jure Export Control ---Administrative System governmental reorganization in 1993 In 1993, the Ministry of Aviation and Space Industry--- China Aviation Industries Corporation, and China Aerospace Industry Corporation. Ministry of Machine Building and Electronics Industry --- Ministry of Machinery Industry and Ministry of Electronics Industry, China Electronics Industry Corporation disbanded. governmental reorganization in 1998 PLA COSTIND was disbanded and recreated as new COSTIND (took over the former COSTIND s functions of defense industrial management, the State Planning Commission s defense department, and those administrative functions held by those national defense industries) ; China Atomic Energy Authority become part of the new COSTIND The military portion of the old COSTIND was transferred to the newly created General Armament Department State Council and CMC Leading Group for Military Product Trade disbanded in March 1998

The major military corporations will be organized into ten enterprise groups China National Nuclear Corporation CNNC Aviation Industries Of China---AVIC China Ordnance Industry Corporation---NORINCO China State Shipbuilding Corporation---CSSC China Aerospace Industry Corporation ----CASC --------------- China National Nuclear Corporation China Nuclear Engineering and Construction Corporation China Aerospace Science and Technology Corporation China Aerospace Machinery and Electronics Corporation China Aviation Industry Corporation I China Aviation Industry Corporation II China State Shipbuilding Corporation China Shipbuilding Industry Corporation China North Industries Group Corporation China South Industries Group Corporation

Delinking of PLA and its business Xinshidai Group (1980, COSTIND) Polytech Incorporated (1983, General Staff Department) Kaili (Carrier) Corporation (1984, General Political Department) Xinxing Corporation (1984, General Logistics Department) Department of Arms Control and Disarmament was developed from the original 4th division in the Department of International Organizations and Conference into a separate department. ---Legal Framework In July, promised to voluntarily report to the IAEA any imports or exports of nuclear materials, nuclear equipment and related non-nuclear materials. In May 1996, promised that it would not offer help to nuclear facilities which had not accepted the IAEA's safeguards, including bans on exports of nuclear materials and personnel or technology exchanges and cooperation. In May 1997, the Chinese government published the Circular on Questions Pertaining to the Strict Implementation of China's Nuclear Exports Policy

In September 1997, Regulations on the Control of Nuclear Export On June, 1998, Regulations on the Control of the Export of Dual-Use Nuclear Materials and Related Technology Export In December 1995, Regulations on the Administration of Controlled Chemicals, Controlled Chemicals List in May 1996 (updated in June 1998) In March 1997, Detailed Rules for the Implementation of the Regulations on the Administration of Controlled Chemicals In October 1997, Regulations on the Control of Military Products Export China published its first white paper China: Arms Control and Disarmament in 1995, and later on in the 1998 and 2002 White Papers on China's National Defense

---China s Relations with arms control and nonproliferation regimes China continued to join in those universally accepted and treaty based agreements China Signed the Additional Protocol with IAEA in December 1998 China supported the negotiation of FMCT, and indefinite extension of NPT,participated in the negotiation of CTBT, provided its support of ABM Treaty in late 1990s China joined in the Zanger Committee (NPT Exporters Committee) in October 1997 China made some political commitment on missile nonproliferation (MTCR) China was not invited to participate in the negotiation of Wassenaar Arrangement China got the chemical list updated in June 1998 to include 10 of the 20 Australia Group chemicals not listed on the CWC schedules. Australia Group was not compatible with CWC should be transformed or abolished The United States invited China to join in those multilateral export control regimes, but China declined the existing discriminatory and exclusive export control mechanisms and arrangements should be overhauled and rectified comprehensively, and a fair and rational international nonproliferation system should be set up through negotiations on the basis of universal participation 1998 white paper

---China s Strategic Trade China s transfer of WMD sensitive materials and technology developed in a downturn China exported some nuclear materials, research reactors and nuclear materials to Ghana (30 kwth Miniature Neutron Source Reactor and enriched uranium) and Nigeria (30 kwth Miniature Neutron Source Reactor and enriched uranium), power reactor Chashma-1 to Pakistan, but all subject to IAEA safeguards. The two 300 MW pressurized water reactors deal with Iran was finally cancelled in 1997 The most controversial transfer of WMD sensitive material is the 5000 ring magnets deal with Pakistan 5000 ring magnets to A.Q. Kahn Research Lab at Kahuta in late 1994 to middle 1995 China stopped the transfer of anti-ship cruise missile to Iran June1998, China made commitment that it would prevent the export of equipment, material or technology that could in any way assist programs in India or Pakistan for nuclear weapons or for ballistic missiles capable of delivering such weapons

---Explanation of China s Policy China involvement in the arms control negotiations bettered China s understanding of international arms control and nonproliferation regimes with the development of Chinese economy, China was more susceptible of external pressure to adhere to global norms and agreements China began to care about its international image. China tried to rebuild its image after 1989, and wanted to be a responsible power rather than a proliferator China has tried to link its attitude and policy toward nonproliferation issues with American arms sale to Taiwan.

1.4 2002-2008 Years of Transformation ---Administrative system MOFTEC ----Ministry of Commerce (MOFCOM) in early 2003 Department of Scientific and Technological Development and Trade in Technology merged into the Department of Electromechanical Products and Science and Technology Industry China made efforts to streamline the export vetting procedure, and coordination among different agencies Lots of Measures issued by MOFCOM or jointly with GAC on registration, administration of license Circular on Customs Clearance of Export License for Sensitive Articles and Technology in December 2002

China has set up a national expert supporting systems for export control in December 2003, and the first group of 240 In May 2004, the Chinese Government established an inter-agency contingency mechanism for export control and spelt out in detail the responsibilities, division of labor and work procedures of relevant export control departments in dealing with emergency cases September 2007, China is encouraging Chinese enterprises to set up Internal Compliance Program (ICP).

---Legal Framework China promulgated some new regulations, control lists, and updating old regulations and control lists in chemical, biological, nuclear, missile items, dual use items and related equipment and technologies (missiles in August 2002, biological in July 2006,chemicals in October 2002, the military control list in November 2002) China revised or updated some of regulations and control lists, including regulations on administration of arms export in October 2002, regulations on nuclear export in November 2006, regulations on nuclear dual-use items and related technologies and its control list in January and July of 2007 respectively. China also implemented some temporary export control measures such as Tri-Butyl- Phosphate and graphite-related products.

---China s Relations with arms control and nonproliferation regimes China provided very positive comments on nonproliferation and arms control in its 2003 White Paper consensus of the international community, conductive to international and regional peace and security, China is learning from and drawing on their useful experience and practices for its own reference China has become more and more deeply involved in nonproliferation export control conferences and discussions with many countries such as US, French, Germany, Japan, South Korea, NATO, Pakistan, seminars jointly sponsored with EU and US, etc. China increased constructive engagement with multilateral export control regimes. joined Nuclear Suppliers Group (NSG) in 2004, and applied to join MTCR in September 2004. China held two-round dialogues with MTCR, three- round discussion with Austria Group and Wassenaar Arrangement since 2003.

---China s Strategic Trade Starting from 2001, Chinese companies have been imposed sanctions by the United States for more than 19 times. These alleged violations of export control were mostly related with Chinese companies trade with Iran on chemical, and missile dual use items and/or technologies. Most of these sanction imposed by Bush administration against Chinese companies involves the WMD related dual use items. US is lowering the threshold to trigger sanctions by citing the executive order as the legal basis for sanctions.. ---Explanation of China s Policy increased recognition of the danger posed by WMD proliferation after 911 make nonproliferation a less sticky issue in bilateral relations China s peaceful rising, the international image matters the regional security is key to china s stability and prosperity Change the negative interaction into positive interaction in nonproliferation issue

2, China s Export Control Process: A Brief Introduction 2.1 Key Players 2.2 Legal Basis 2.3 General Process of the export control licensing system

2.1 Key Players Ministry of Foreign Affairs (The Department of Arms Control and Disarmament) Evaluate proliferation risk (the end user through embassies), the potential impact on China s foreign policy. Interpret China s international commitment Attend inter-agency coordination of those major/controversial exports. Training and educating industry (supporting role), Point of contact for nonproliferation related intelligence sharing Ministry of Commerce (Department of Electromechanical Products and Science and Technology Industry, and the Quota & License Administrative Bureau, Department of Foreign Trade) Involved in all export control decision except military product Registration in Department of Foreign Trade to get authority to import or export goods from or to China Obtain permission to export of sensitive goods and technology from Department of Electromechanical Products and Science and Technology Industry

Review all export application for all dual use sensitive goods and technology Coordinate interagency consultation Issue the license for most of those approved export applications by the Quota and License Bureau (once approved) Implementation and Enforcement Leading the training and education of export control regulations, rules, circulars Leading the government to industry outreach Investigating of illicit exports of sensitive goods and technology Punishing those violators (administrative fines) China Atomic Energy Authority (The Department of International Cooperation, the fifth division) Reviewing and licensing exports of nuclear materials in the form of (Piwen) Approved Document (approval or rejection), nuclear equipment, and non nuclear goods used in nuclear power reactor (if approved, the case will go to MOFCOM for further review, or Foreign Ministry or State Council) Reviewing the technical analysis for end use of the export Providing advice for export of dual use nuclear goods (recommend for license), modification of nuclear related regulations, and control list

Commission on Science, Technology, and Industry for National Defense (The Department of International Cooperation, the fifth division (division of Nuclear Issue and International Organization) The overlapping authority with CAEA in vetting exports of nuclear and dual use nuclear goods and technology Responsible for preparation, implementation and supervision of national defense S&T plans, policies, standards and regulations Review export application for conventional military product and make decision (division of military product trade) International cooperation and exchange on behalf of CAEA Participate the training and education (responsibility including arms control and nonproliferation research related with national defense industry and compliance) National Chemical Weapons Convention Implementation Office (part of the National Development and Reform Commission) Review export application for controlled chemical goods according to CWC Implement the CWC (compliance) Training and education

General Administration of Customs (Policy and Regulations Department) Prevent illicit exports, final inspection Rapid reaction Receive license notification in writing from MOFCOM, and check the category and quantity of exported items Investigation in the area of its jurisdiction Training and education Ministry of Public Security Enforcement Investigate possible illicit exports (the economic crime bureau)

2.2 Legal Basis Domestic law, International Treaties, and China s commitment are the main sources of the export control legal framework The Foreign Trade Law (article 16, 17, created in 1994, revised in 2004) The Custom Law (article 6, 24, 40, promulgated in January 1987, amended in July 2000) The Criminal Law (article 225, and Amendment No.3 of 2001) The Administrative Punishment Law (promulgated in March 1996) Regulations of the PRC on the Import and Export Control of Technologies (promulgated in December 2001) Regulations of the PRC on the Import and Export Control of Goods (promulgated in December 2001) Nuclear Export (September 1997, revised in November 2006) Dual-Use Nuclear(June 1998, revised January 2007) Measures on the Administration of Approval for Transfer and Transit of Nuclear Items(January 2000) Dual-Use Biological(October 2002) Control list (September 2006)

Controlled Chemicals (December 1995) Controlled Chemicals List (May 1996, supplemented in June 1998) Detailed Rules for the Implementation of the Regulations on the Administration of Controlled Chemicals (March 1997) Measures on the Export Control of Certain Chemicals and Related Equipment and Technologies, and control list (October 2002) Missile and Control list (August 2002) Arms export (October 1997, amended in October 2002) Control List November 2002) Measures on the Administration of Export Registration for Sensitive Items and Technologies (November 2002) Measures on the Administration of Export Licenses on Dual Use Items and Technologies (December 2005) Export Licensing Catalogue of Sensitive Items and Technologies (December 2003, update almost annually) International arms control and nonproliferation treaties

China s political commitment Missile: February 1992/October 1994/October 1997/June 1998 November 2000 Nuclear: Three principles Military product: Three principles

2.3 General Process of the export control licensing system Step 1, Chinese entity to register with Department of Foreign Trade of MOFCOM to get authority to import or export goods from or to China Step 2, Chinese entity to apply for authorization or registration to export dual use nuclear, chemical, missile items and technology Step 3, China entity to apply license for the export of controlled items and technology, the following documents should be provided when applying for license 1. Application form 2. Identification of the applicant s legal representative, chief managers, and the person(s) handling the deal 3. Duplicates of the contract or agreement 4. Technical specifications of the items 5. End-user and end-use certificates 6. Documents of guarantee assuring no third-party transfers and no unintended usages

7. Introduction of the end user 8. Other documents as may be required by the competent foreign economic and trade department of the State Council. Step 5, MOFCOM/CAEA/COSTIND/NCWCIO review the application on a interagency basis if necessary, the national expert supporting systems for export control may be involved in this process, also MFA, or State Council and CMC Step 6, If application approved, the license will be issued by the Quota and License Bureau of MOFCOM Step 7, The exporter will clear the Custom with the license and other documents required by the regulations

3, China s Export Control Achievements and Challenges 3.1 Achievements The biggest change is China s attitude toward nonproliferation export control: from outsider to insider It translated its commitment into laws and regulations. Significant efforts have been made to implement and enforce its policies China did begin to increase transparency in export control policy, decision making, punishment, violators China has de-linked nonproliferation issue with other issues.

3.2 Challenges There is quite a lot of work to do regarding training and education. Inter-agency cooperation and communication need to be expanded vertically and horizontally challenges come from the increasing industries which export WMD-related items or technologies. --- small and medium enterprises (SME) --- lowered threshold for foreign trade Issue of Internal Compliance Program Government and industry interaction

4. Conclusion and Recommendations Major powers should change their negative attitudes toward or export control policy against China Encourage and support china s membership in multilateral export control regime is one way to further China s nonproliferation cooperation with major powers. Other major powers could come to help in China s capacity building

Thank you all! Questions and Comments? Jishe_Fan@ksg.harvard.edu

State Council designated exporters Nuclear China National Nuclear Corporation (China Zhongyuan Engineering Corporation equipment and material, China Nuclear Energy Industry Corporation technology and equipment) Chemical Sinochem International Corporation SINOCHEM China Petroleum & Chemical Corporation---SINOPEC China Haohua Chemical (Group) Corporation Conventional Military product 保 利 科 技 有 限 公 司 Poly Technologies Corporation (General Staff Department) 新 时 代 科 技 有 限 公 司 Xinshidai (New Era) Technology Development Corporation

中 电 科 技 国 际 贸 易 有 限 公 司 China National Electronics Import-Export Corporation 中 国 北 方 工 业 公 司 China North Industries Corporation 中 国 船 舶 工 业 贸 易 公 司 China Shipbuilding Trading Company 中 国 京 安 进 出 口 公 司 Jingan Equipment Import-Export Corporation 中 国 航 空 技 术 进 出 口 总 公 司 China National Aero-Technology Import- Export Corporation Group (Aviation Industries Corporation of China) 中 国 精 密 机 械 进 出 口 总 公 司 China National Precision Machinery Import and Export Corporation (China Aerospace Corporation) 中 国 电 子 进 出 口 总 公 司 China National Electronics Import-Export Corporation 中 国 新 兴 进 出 口 总 公 司 China Xinxing Import and Export Corporation

ICP: example of NORINCO efforts ---NORINCO has been sanctioned numerously (May 03, July 03, September 03 April 04, September 04, December 04, December 05) --- NORINCO recruited one graduate from Tsinghua University tentatively to set up its ICP --- invited governmental officials, experts and scholars to contribute suggestions in building up a more effective ICP --- trained all the employees involved in export related activities --- published Corporate principles governing internal export control on WMDrelated items --- formally set up ICP Council and ICP Office --- developed some cooperations with Chinese research institutions --- training done by James Martin Center for Nonproliferation Studies at Monterey Institute of International Studies ---assistance from Center for Trade and International Security at University of Georgia.