China's Non-Proliferation Export Control

1
China's Non-ProliferationExport Control

• Li Genxin
• Secretary General
• China Arms Control and Disarmament Association
  (CACDA)

2
Presentation Outline

• Basic Policy
• Relations with Multinational XC Mechanisms
• Key Elements of China XC
• Case Study ICP in NORINCO

3
Presentation Outline

• Basic Policy
• Relations with Multinational XC Mechanisms
• Key Elements of China XC
• Case Study ICP in NORINCO

4
China's Basic Policy and Position on
Non-Proliferation

• China firmly opposes WMD proliferation and their
  means of delivery
• China believes that proliferation of WMD has
  complicated root causes. In order to prevent
  their proliferation, an integrated approach must
  be adopted to address both the symptoms and the
  root causes.
• Chinese Government has adopted comprehensive
  measures to implement non-proliferation and
  export control obligation.

5
Presentation Outline

• Basic Policy
• Relations with Multinational XC Mechanisms
• Key Elements of China XC
• Case Study ICP in NORINCO

6
Actively Participating in International
Non-Proliferation Efforts

• NPT Since joining NPT in 1992, China has
  faithfully honored all its obligations and
  dedicated itself to maintaining and enhancing the
  universality, effectiveness and authority of the
  NPT.
• IAEA China joined IAEA in 1984. In early 2002
  formally completed the domestic legal procedures
  necessary for the entry into force of the
  Additional Protocol, thus becoming the first
  nuclear-weapon state to complete the relevant
  procedures.
• BWC China acceded to the BWC in 1984, and has
  always supported and actively participated in the
  multilateral endeavors aimed at strengthening the
  effectiveness of the Convention.
• CWC As an original State Party to the CWC, China
  has made positive contributions to the effective
  implementation of the Convention and promotion of
  its universality. China has established and been
  constantly improving its national legislation and
  other measures for implementation of the
  Convention, as well as enhancing the capabilities
  of its National Authority. By the end of June
  2005, China has received 95 on-site inspections
  by the OPCW, the conclusions of which have all
  demonstrated that China has strictly implemented
  its obligations under the Convention.

7
Developing Relations with Multinational Export
Control Regimes

• Zangger Committee (October 1997)
• Nuclear Suppliers Group (June 2004)
• MTCR (Sept 2004 application for membership)
• Australia Group (keep contacts and exchanges)
• Wassenaar Arrangement (April 2004 and May 2005,
  China held two rounds of dialogues with AG in
  Vienna)
• Dialogue and consultation with all
  concerned countries, e.g. US, UK, FR, GE,SW, IT,
  JP, AU, ROK, etc.
• Participation in international and
  regional conferences and seminars

8
Presentation Outline

• Basic Policy
• Relations with Multinational XC Mechanisms
• Key Elements of China XC
• Case Study ICP in NORINCO

9
Key Elements of China XC

• Legal framework
• Licensing system
• Control list
• Inter-agency coordinating system
• End-use and end-user guarantee
• Catch-all principle
• Enforcement
• Social awareness and compliance

10
Legal System on Non-Proliferation Export Control

• Since the mid-1990s, China has gradually set up a
  comprehensive legal system for export controls of
  nuclear, biological, chemical, missile and other
  sensitive items and technologies as well as all
  military products.

11
XC Laws and Regulations

• 1994 Foreign Trade Law Of PRC, Revised in 2004
• 1995 Regulations on Administration of Controlled
  Chemicals of PRC
• 1997 Regulations on Nuclear Export Control of PRC
  (Under review)
• 1998 Regulations on Export Control of Nuclear
  Dual-use Items and related Technologies of PRC
  (Under review)
• 1998 Regulations on Arms Export of PRC, Revised
  in 2002
• 2002 Regulations on Export Control of Missiles
  and Missile-Related Items and Technologies of PRC
• 2002 Regulations on Export Control of Dual-Use
  Biological Agents and Related Equipment and
  Technologies of PRC (Amended in July 2006)
• 2002 Measures on Export Control of Certain
  Chemicals and Related Equipment and technologies
  of PRC
• 2002 Measures on the Administration of Export
  Registration for Sensitive Items and Technologies
• 2003 Provisional Measures on the Administration
  of Export Licenses on Sensitive Items and
  Technologies

12
Recent XC legal developmentsand temporary
measures

• 2004 Foreign Trade Law Of PRC, Revision
• 2005-01-01 Measures for the Administration of
  Licenses for the Export of Goods (MOFCOM Order
  No.28)
• 2005-12-01 Reform of the Administrative Approval
  System for the Import and Export of Sensitive
  Items and Technologies (MOFCOM Circular No. 548)
• 2006-01-01 Measures for the Administration on
  Import and Export License for Dual-Use Items and
  Technologies (MOFCOM and GAC Order No. 29)
• 2006-07-27 Notice No.50 on Nuclear Dual-Use Items
  (COSTIND and GAC)
• 2006-07-31 Regulations on Export Control of
  Dual-Use Biological Agents and Related Equipment
  and Technologies of PRC (Amended in July 31, 2006
  MOFCOM Notice No.61)
• 2006-08-01 Management of Civil Aviation Parts
  Export Classification (MOFCOM and GAC Order No.6)
• 2006-09-07 Regulations on the Management of
  Verification of Import and Export of Precursor
  Chemicals (Public Security Bureau, MOFCOM Order
  No.8)

13
Legal Obligations

• Without registration, no one or unit can export
• Submitted application materials should be true
  and complete. All records of a transaction
  should be kept for at least 2 years
• Exporting controlled items or technologies
  without being licensed or exceeding the license
  scope is prohibited
• Forging, altering, buying and selling the license
  is prohibited
• Obtaining the license by fraud or other illegal
  means is prohibited
• Violators will get administrative punishment or
  criminal judgment. (Shanghai and Jilin open
  cases)

14
Basic Principles Set in the Regulations

• Exporter Registration System
• Licensing System
• List Control with HS Code
• End-user and End-use Guarantee
• Catch-all Principle
• Legal Obligations and Penalties

15
Export Registration System

• Exporter must get registered at government
  department
• Without registration, no individual or entity
  could export sensitive items and technologies.
• (Arms, Nuclear and Some Controlled Chemical
  Items are Monopolized or exclusive)
• (A lot of area are governed by double register
  system license for qualification, license for
  export item)

16
Licensing System

• Export means service, technical exchange, foreign
  assistance, etc. as well as physical transaction
• All export of SGT should be licensed by a
  competent government agency in concurrence with
  other agencies concerned
• Applications are handled on a case-by-case basis
• Dispute resolution system (escalating system)
• Legal time limit for licensing is 45 days. ( Not
  applicable to those submitted to State Council)
• Adoption of a website-based electronic system to
  facilitate application

17
Control List

• Nuclear Fully matched with NSG ZC lists
• Biological Fully matched with AG list (2002.6)
• Chemical Fully matched with AG list (2002.6)
• Missile Compatible to MTCR list

18
End-user and End-use Guarantee

• The end-user must guarantee
• not to use the imported items and technologies
  for purposes other than the declared end-use
• Not to transfer the imported items and
  technologies to any third party other than the
  declared end-user without consent of the Chinese
  government

19
Catch-All Principle

• Where the exporter knows or should know that the
  missile-related items and technologies to be
  exported will be used by the receiving party
  directly in its program for developing missiles
  and other delivering systems listed in the
  Control List that can be used to deliver weapons
  of mass destruction, the export shall be subject
  to the provisions of these Regulations even if
  the items or technologies are not listed in the
  Control list.
• --- Article 16 in the Missiles Export Control
  Regulations

20
GOVERNMENT COORDINATION

• 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 in this respect.
• Inter-agency coordinating system
• (licensing, intelligence, enforcement and
  expertise support)
• Fast reaction system
• (for suspected cases calling for immediate
  action)

21
GOVERNMENT AGENCIES CONCERNED

• Ministry of Commerce (MOFCOM)
• Ministry of Foreign Affairs (MFA)
• National Development and Reform Committee (NDRC)
• Commission of Science and Technology Industry of
  National Defense (COSTIND)
• Ministry of Agriculture (MOA)
• Ministry of Health (MOH)
• Customs, and etc.

22
Non-Proliferation Export Control Organs

• China's non-proliferation export control involves
  many of the government's functional departments.
  So far, a mechanism for a clear division of
  responsibility and coordination has been
  established among these departments.
• MOFCOM The export of nuclear dual-use items,
  dual-use biological agents, certain chemicals,
  and the missile-related dual-use items and
  technology for civilian use is under the control
  of the Ministry of Commerce (MOFCOM), in
  coordination with other government departments
  concerned.
• COSTIND Among them, the export of nuclear
  dual-use items and missile-related dual-use items
  and technologies is subject to examination by the
  MOFCOM, in coordination with the Commission of
  Science and Technology and Industry for National
  Defense (COSTIND).
• MOA The export of dual-use biological agents and
  technologies related to animals and plants is
  subject to examination by the MOFCOM, in
  coordination with the Ministry of Agriculture
  (MOA) if needed.
• MOH The export of dual-use biological agents and
  technologies related to humans is subject to
  examination by the MOFCOM, in coordination with
  the Ministry of Health (MOH) if needed.
• SDRC The export of equipment and technologies
  related to dual-use biological agents and of
  equipment and technologies related to certain
  chemicals is subject to examination by the
  MOFCOM, in coordination with the State
  Development and Reform Commission (SDRC) if
  needed. The export of controlled chemicals is
  subject to examination by the State Development
  and Reform Commission, in coordination with the
  MOFCOM
• MFA The export of sensitive items and related
  equipment and technologies that relate to foreign
  policy is subject to examination by the
  above-mentioned competent departments, in
  coordination with the Ministry of Foreign Affairs
  (MFA).
• GAC The General Administration of Customs (GAC)
  is responsible for supervision and control of the
  export of the above-mentioned items and
  technologies, and it also participates in
  investigating and handling cases of illegal
  exports.
• State Council Where the export items entail
  significant impact on national security and
  public interests, the competent departments
  shall, jointly with other relevant departments,
  submit the case to the State Council and the
  Central Military Commission for approval

23
NUCLEAR MATERIALS
24
NUCLEAR EQUIPMENT NON-NUCLEAR MATERIAL USED FOR
REACTORS
25
NUCLEAR DUAL-USE ITEMS TECHNOLOGIES
26
CONTROLLED CHEMICALS
27
SENSITIVE DUAL-USE ITEMS TECHNOLOGIES
(Including Biological, chemical and missile)
28
Rigorous Implementation of Laws and Regulations
on Non-Proliferation Export Control

• In January 2004, the MOFCOM and the GAC jointly
  launched a computer control system for the export
  of sensitive items and technologies by connecting
  within the same network different agencies that
  approve and issue the license with the
  supervision branch of the Customs.
• Based on control lists for nuclear, biological,
  chemical and missile exports, the MOFCOM and the
  GAC jointly compiled the Export Licensing
  Catalogue of Sensitive Items and Technologies
  covering 658 items and technologies, of which 68
  have had their customs code determined.
• China's Customs also extensively apply hi-tech
  equipment in various links in the process of
  supervision and control of customs clearance,
  which has significantly upgraded the capacity of
  on-site law enforcement and efficiency of
  examination
• Since the end of 2002, the Chinese Government has
  dealt with scores of cases of various types
  concerning illegal export of sensitive items and
  technologies. Competent authorities have put the
  companies involved in these cases on a "watch
  list" so as to prevent the recurrence of similar
  activities.
• Relevant competent authorities have set up a
  "national expert supporting system for export
  control" that engages experts from nuclear,
  biological, chemical and missile fields to assist
  competent authorities in making correct and
  scientific judgments on relevant items during the
  process of export examination and approval

29
Outreach and Education

• A very important part of the whole XC system
• Co-efforts contributed by government and industry
  to nonproliferation
• Help to detect and avoid possible proliferation
  in advance
• foster and maintain a good interactive relation
  with industries
• Objectives of Outreach
• To raise public awareness of XC
• To guide and assist firms understand and abide by
  national policies and regulations
• To help firms to establish ICP, and assist them
  to analyze and decide the risk of a suspected
  transaction
• To listen to the industry need and recommendation
  on XC regulations and procedures for improvement
• To consult industries on actual item for
  professional and expertise opinions

30
Outreach Channels

• Government Publications (Gazette)
• Website (MOFCOM/MOFA)
• Hotline
• Training Courses
• Seminars
• Individual Contacts (Upon request)
• Contacts through chambers and industry
  associations (imp/exp chambers, machinery
  industry association, CACDA, etc.)

31
Major Activities

• Training of Officials from Local Commerce
  Departments and Customs Officers
• Training of Exporters Dealing with SGT exports
• Seminars with Technical Experts
• Seminars with Think-Tanks
• On-site visit to Individual Companies
• Co-hosted XC Seminars with USDOC in 2000 and 2003
• Organizing Industries to Participate in
  International Meetings and Seminars

32
Greater Publicity for Laws and Regulations on
Export Control and Education for Enterprises

• The Chinese Government attaches importance to
  educating and training law enforcement officials
  for export control, especially those at the
  grass-roots level, so as to raise their policy
  awareness and capability to exercise export
  control according to law.
• After the release of relevant laws and
  regulations on export control, the MOFCOM carried
  out comprehensive training programs on policies,
  laws and regulations for commerce officials at
  local levels.
• In places prone to cases of illegal export, the
  MOFCOM also holds, on non-regular basis, special
  training courses on policies, laws and
  regulations and law-enforcement of export
  control.
• The GAC, jointly with relevant organs in charge
  of non-proliferation export control, conducted
  training programs for on-site customs officials
  across the country on policies, laws and
  regulations with regard to the export control of
  sensitive items and technologies.

33
Greater Publicity for Laws and Regulations on
Export Control and Education for Enterprises

• To publish the full text of laws and regulations
  on export control on the web sites of competent
  government departments
• To get export enterprises familiarized, by
  organizing regular training courses and lectures
  and distributing pamphlets, with policies, laws
  and regulations on export control as well as the
  procedures for export examination and approval to
  ensure that the enterprises implement them in
  real earnest and run their business according to
  law
• To set up a hotline to timely clear up doubts or
  questions from the enterprises and to
  investigate and punish illegal exporters and make
  them public.
• To encourages and guides the enterprises to build
  their own internal mechanisms for
  non-proliferation export control and implement
  accountability for non-proliferation in
  accordance with their own specific situations.
• Some enterprises have set up offices for
  non-proliferation export control to disseminate
  information of relevant national policies and
  legislation, draw up specific measures for
  implementation within the enterprises, and
  supervise their own scientific research,
  production and business operations so as to
  ensure that the enterprises abide by national
  laws and regulations.

34
Future Priority

• General training and education
• Licensing related consulting (regulations and
  procedure)
• ICP

35
Presentation Outline

• Basic Policy
• Relations with Multinational XC Mechanisms
• Key elements of China XC
• Case Study ICP in NORINCO

36
NORINCO Introduction

• China North Industries Corporation (NORINCO) ,
  formally established in 1980 with approval of the
  Chinese government, is a giant enterprise group
  engaged in both products operation and capital
  operation, integrated with RD, manufacturing,
  marketing, and services. NORINCO mainly deals
  with defense products, petroleum mineral
  resources exploitation, international engineering
  contracting, optoelectronic products, civilian
  explosives chemical products, sports arms
  equipment, vehicles and logistics operation, etc.
  NORINCO has been ranked among the forefront of
  Chinas 500 largest state-owned enterprises in
  terms of total assets and revenue.

37
NORINCO ICP Elements

• Management Commitment
• Concrete Measures
• ICP Offices
• Export Compliance Instruction Manual
• ICP Intranet
• ICP Training
• Management System
• Screening System
• Recordkeeping
• Auditing
• Encouragement and Penalty

38
The Commitment on Nonproliferation Export
Compliance Signed by the President of NORINCO

• NORINCO holds firmly the position that
  proliferation of WMD and their means of delivery
  is conducive neither to world peace and
  stability, nor to Chinas security, and is
  absolutely in contrary to its value of a
  responsible corporation for the benefit of
  international community.
• NORINCO affirms its unequivocal and emphatic
  support for Chinese governments policies
  regarding non-proliferation of Weapons of Mass
  destruction (WMD) and their means of delivery. As
  an authorized defense products and services
  supplier, in recognition of the sensitive nature
  of its core business, its responsibility of
  non-proliferation and its obligation of export
  control compliance, NORINCO commits to abide by
  Chinese governments non-proliferation and export
  control laws and relevant law enforcement fully
  and uncompromisingly.
• Effective export controls must be a combined
  effort between governments and companies. In
  response to Chinese governments endeavor to
  strengthen non-proliferation and export control
  law enforcement, NORINCO chooses to take the lead
  of non-proliferation and export control
  compliance on corporate level.
• Under the guidance of Chinese government
  agencies, specifically Ministry of Foreign
  Affairs, Commission of Science, Technology and
  Industry for National defense (COSTIND) and
  Ministry of Commerce (MOFCOM), by adopting
  international best practice, NORINCO actively
  pursues a sound internal compliance programs
  (ICP), which prove to be a major improvement for
  corporate internal control in compliance with
  Chinese governments law enforcement
  requirements, such as export registration,
  license, end-user and end-use certification,
  control list and relevant export control
  examination and approval.
• All NORINCO employees will actively assist in the
  achievement of the corporate goal of export
  compliance. In particular, NORINCO employees
  involved in the export of the companys products,
  technology, and services will be familiar with,
  and strictly abide by, all applicable provisions
  of export control laws and regulations. NORINCO
  holds all executives of export-related divisions
  and subsidiaries account for the responsibility
  of non-proliferation and export control
  compliance.
• By taking catch-all principal for export control,
  NORINCO attaches clear-cut and unambiguous
  priority to the goal of non-proliferation of WMD
  and their means of delivery over commercial
  interests. In practice, this means that even if a
  particular export transaction is legal according
  to export control laws and regulations, NORINCO
  in accordance with its corporate policy of
  voluntary self-restraint in export matters will
  neither directly nor indirectly supply products,
  technology or services if NORINCO has reason be
  believe that such items could be used by its
  customer or end-user for the development or
  production of WMD and their means of delivery.
  
• In order to ascertain what products, technology
  and services, as well as which customer and
  end-user, should be regarded as sensitive,
  NORINCO will establish and maintain contact with
  all responsible Chinese government agencies,
  relevant NGOs and non-proliferation and export
  control experts for information, instruction and
  advice.
• Proliferation of WMD and their means of delivery
  represents a global challenge, NORINCO deems it a
  necessity to confront the challenge through
  international cooperation. International
  community should enhance mutual understanding
  through confidence building. NORINCO attaches
  importance to and actively participates in
  international best practice sharing and
  cooperation on non-proliferation. For the purpose
  of continuous improvement of its internal
  compliance programs, NORINCO is open to cooperate
  and share compliance knowledge with its
  international peers, non-proliferation research
  institutes as well as foreign
• government agencies.
• This policy applies to all divisions and
  subsidiaries of NORINCO worldwide. The principles
  incorporated herein have been fully implemented
  within the framework of NORINCOs existing
  internal compliance programs. This policy will
  continuously be reviewed and audited in order to
  incorporate the latest development of
  non-proliferation and export control.

39
Concrete Measures

• Authorizing ICP Office with Veto Power
• Drawing up Guidance Advice of NORINCO on
  Nonproliferation Export Control
• 1, Improving the importance on export
  compliance, and doing business on the basis of
  nonproliferation
• 2, Founding and advancing ICP in NORINCO
• 3, Strictly implementing the regulations,
  and attaching primary importance to high risk
  fields
• 4, Strengthening the training and education
  on nonproliferation export control.
• Signing the Letter of Responsibility on
  Nonproliferation Export Control

40
ICP Offices
41
Offices Responsibilities

• ICP Council
• ICP Council is the top management body in
  NORINCO on nonproliferation export compliance.
  The members of ICP Council include vice
  presidents and managers of the departments
  related export, such as ICP Office, Strategic
  Management Department, Finance Department and
  Legal Affairs Department. In charge of overseeing
  regulations and work goals on nonproliferation
  export compliance, determine the principles and
  plans on how to deal with serious compliance
  failure and authorize ICP Office to strictly
  manage high risk businesses.
• ICP Office
• ICP Office is the standing body to implement
  the compliance program and address the day-to-day
  export control issues. Its responsibilities
• 1, Following the development of
  international nonproliferation and studying the
  impact on international military products trade.
• 2, Grasping the laws, rules and regulations
  of the government on nonproliferation export
  control and keeping all employees of NORINCO
  updated on regulatory changes
• 3, Drawing up the regulations on
  nonproliferation export compliance, and
  implementing them after the approval of ICP
  Council.
• 4, According to the instruction of
  President and ICP Council, ICP Office checks the
  sensitive business, and exercises the power of
  veto.
• 5, Appointing the functional personnel to
  screen export contracts related sensitive
  countries, regions and sensitive items.
• 6, Applying for registration of dual-use
  items and technology export from MOFCOM
• 7, Organizing the internal training on
  nonproliferation export control, and enhancing
  the communication with relevant governments and
  NGOs

42
Export Compliance Instruction Manual

• NORINCO has compiled Manuals on Nonproliferation
  Export Compliance since 2003, which have been
  distributed to all employees.
• The manuals contain all international conventions
  on nonproliferation, all relevant laws,
  regulations and control lists issued by Chinese
  government, as well as the policies and
  procedures of export compliance in NORINCO.
• The manuals contain all international conventions
  on nonproliferation, all relevant laws,
  regulations and control lists issued by Chinese
  government, as well as the policies and
  procedures of export compliance in NORINCO.
• ICP Office closely follows up the scent of
  international and internal
• nonproliferation and keeps the manuals current.

43
ICP Intranet

• NORINCO sets a column on nonproliferation in the
  intranet which will be updated.
• The column contains the electronic version of the
  Manuals on Nonproliferation Export Compliance,
  the latest tendency of nonproliferation and new
  measures taken by the company, which provides
  evidence for the
• employees to consult the laws and rules they need
  while a problem arise.
• Export compliance intranet is a platform of
  training on export compliance

44
ICP Training

• ICP Office organizes trainings on
  nonproliferation export control for all employees
  involved in export annually.
• 1, New Employees / Once a Year
• 2, Employees Involved in Defense Export /
  Twice a Year
• 3, Employees Involved in Export from
  Subsidiaries / Once a Year
• 4, Employees of Overseas Branches / Once a
  Year
• 5, Retired Employees / Once a Year
• Assigning employees at various level
• to receive professional training
• by the government or NGOs.
• Assigning employees from administra-
• tion, sales and law units to go abroad
• for professional training.

45
Some Practices

• NORINCO has to apply for export license from
  government agencies in charge of export control
  according to Regulations of the PRC on
  Administration of Arms Export.
• NORINCO has standardized business processes, and
  put a high emphasis on inquiry as starting point
  of process.
• Cooperating with famous company abroad, NORINCO
  has implemented advanced ERP system to
  standardize business processes.
• NORINCO actively interacts with the government
  ministries and places itself under guidance.
• NORINCO has actively used government resources,
  and founded the experts consultant system on
  nonproliferation export control.

46
Management System

• ERP Management System
• Cooperating with famous company abroad,
  NORINCO has imported and implemented the
  international standard ERP system.
• Screening System
• 1, As for export contracts related sensitive
  countries, items or technologies, NORINCO will
  strictly examine the information of buyers and
  end-user and end-use certificate in order to
  prevent the diversion risk of these items or
  technologies.
• 2, The sensitive business is
• handled and screened on
• the case-by-case basis.
• All inquiries and offers are
• evaluated and monitored.

47
Screening System

• Customer Screen System
• Order Screen System
• Products Screen System

48
Customer Screen System
49
Order Screen System
50
Products Screen System
51
Recordkeeping

• NORINCO has founded Documents Management Office,
  and identified specific persons to maintain all
  records of transactions.
• NORINCO continuously improves the information
  management systems and perfects the database of
  export in which the history transactions can be
  easily found out.
• 1, Keep specific records eternally
• 2, For common transactions, identify the
  period of time records must be kept according to
  relevant regulations
• 50 years 15 years

52
Auditing

• NORINCO audits defense transaction every year.
• 1?Audits on ICP.
• 2?Random audits on the transactions related
  sensitive countries and items.
• ICP Office regularly audits the export
  transactions of subsidiaries with Audit
  Department of NORINCO.
• China Arms Control and Disarmament Association
  (CACDA) assess the effect of ICP in NORINCO every
  year.

53
Encouragement and Penalty

• The work of export compliance at different levels
  must be reflected in their performance
  evaluations.
• The employee who doesnt comply with the
  companys regulations will be subject to the
  heavy penalty. If he violated Chinas export
  control laws and rules, he should be subject to
  criminal or civilian penalties.

54
Conclusion

• Basic Policy
• Relations with Multinational XC Mechanisms
• Key Elements of China XC
• Case Study ICP in NORINCO

55
Thank You !

• My Contact
• Mr. Li Genxin
• Secretary General
• China Arms Control and Disarmament Association
• 3, Toutiao, Taijichang, Beijing, 100006
• Telephone[phone]
• Email ligenxin_at_hotmail.com