Beijing has released a new white paper, China’s Endeavors for Arms Control, Disarmament and Non-Proliferation.
The white paper looks to be somewhat longer than its predecessor (released in 2003), with an expanded section covering the implementation and publication of export control laws.
Implementation strikes me as the major challenge facing China, particularly with regard to missile components. The problem was captured in a recent 721 report from the CIA:
Although Beijing has taken some steps to educate firms and individuals on the new missile-related export regulations—offering its first national training course on Chinese export controls in February 2003—Chinese entities continued to work with Pakistan and Iran on ballistic missile-related projects during the first half of 2003.
China offered a second seminar in September 2003.
The very best monograph that I’ve read on the subject is Export Controls in the People’s Republic of China by Jonathan E. Davis at the University of Georgia’s Center for International Trade and Security.
One of Davis’ footnotes captures massive task of educating many small Chinese firms about new export control regulations:
One example of onerous licensing requirements cited by a Chinese expert concerns the export of aluminum tubing with a particular diameter or larger. According to the expert, the Chinese government adopted an entire international control list without soliciting comments from industry and therefore was unaware that many small Chinese companies export aluminum tubing for fireworks, soldering, and other legitimate purposes, while most other countries export only very small numbers of these items. With current controls in place, exporters must apply for a case-by-case license to export such items, greatly burdening small exporters that rely on high volumes of sale for survival and lack the resources to devote full-time to obtaining export licenses. Such an example highlights the difficulties that China may face in reconciling its legitimate commercial interests with its commitments to nonproliferation as it brings its system up to international standards.
I’ve heard the same story. In my case the interlocutor noted something like “Have you looked around? We have many small fireworks companies.”
I attended a talk by Li Bin, a professor at Tsinghua University, in 2002 after Beijing issued new export control regulations. He noted the Chinese export control system restricts the export of aluminum powder used to paint heating devices in homes:
It is noticeable that the Control Regulations are relevant to not only the defense industry but also many high-tech and traditional civilian industries and research institutes. We suggest all relevant entities to pay enough attentions to protect their legal export business. Here is a hypothetical case. A construction supplier company received an order of a foreign company purchasing aluminum powder with diameter less than 0.5 millimeters for painting heating equipments in houses. Although the order has nothing to do with missiles, the construction supplier company still needs to apply for an export license according to the Control Regulations and to provide explanation about the end-user (the foreign company), end-use (painting heating equipments in houses) and the recipient’s assurance. This is because tiny aluminum powder could be used as missile fuel. As long as the end-use can be guaranteed, the exporter should be able to receive the license. The export will be denied by the custom without a license, or be delayed if applying the license later. If the aluminum is shipped without a license, the exporter will receive administrative or legal punishment.
Note: In Part II of the English-version Control List, the unit of the sizes of item 4 (Solid Propellant and Propellant Constituents) is incorrect. They should be 500 µm (micron), not 500 mm (millimeter).
From googling a bit, aluminum powder with a diameter less than 500 µm seems commercially available in the US. I’ll know when Scott Gearity gets back from vacation.
Indeed, Scott delivers with a stab at the commercial availability of aluminum powder and additional thoughts on China’s relationship to the MTCR.