VZCZCXYZ0017
RR RUEHWEB

DE RUEHHK #0913/01 0890518
ZNR UUUUU ZZH
R 300518Z MAR 07
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 1147
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 000913 
 
SIPDIS 
 
USDOC FOR 532/OEA/LHINES/DFARROW 
USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR 
WILLIAM ZARIT 
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS 
 
SIPDIS 
 
E.O. 12958: N/A 
TAGS: BMGT BEXP HK ETRD ETTC
SUBJECT: EXTRANCHECK: POST SHIPMENT VERIFICATION: 
TEGENT TECHNOLOGY LTD. 
 
REF: A) USDOC 02348 
 
1.Unauthorized disclosure of the information 
provided below is prohibited by Section 12C of the 
Export Administration Act. 
 
¶2. As per reftel A request and at the direction of 
the Office of Enforcement Analysis (OEA) of the 
USDOC Bureau of Industry and Security (BIS), 
Export Control Officer Philip Ankel (ECO), 
accompanied by Commercial Assistant Sandy Lai, 
conducted a post shipment verification (PSV) at 
Tegent Technology Ltd. (Tegent), Room 2103-05, 
Westin Center, 26 Hung To Rd., Kwun Tong, Hong 
Kong.  The items in question are a gas 
chromatograph and an electrical mass spectrometer 
exported to Tegent on or about December 18, 2006 
with a combined value of approximately USD 30,000. 
On the applicable shippers export declaration 
(SED), these items are classified as 3A999.  Items 
properly classified as 3A999 may be 
exported/reexported license free to virtually all 
destinations and end-users worldwide, except 
certain terrorist sponsoring countries (including, 
in particular, North Korea).  The exporter was 
Agilent Technologies of New Castle, Delaware 
(Agilent). 
 
¶3.  According to the Hong Kong Companies Registry, 
Tegent has been in existence since 1993.  It has 
registered share capital of HKD one million 
(approximately USD 125,000).  Directors are Hong 
Kong identity card holders Hon Ching Cheung, Yan 
Chiu Yu and Yan Oi Yu.  According to Tegent's web 
site (www.tegent.com.hk), the company is a leading 
provider of high technology testing instruments to 
customers in mainland China.  Tegent lists typical 
customers as laboratories involved in 
environmental monitoring, food analysis, R&D and 
petroleum product testing. 
 
¶4.  The ECO and Commercial Assistant Sandy Lai 
visited Tegent at the address referenced above on 
March 27, 2007 and met with Mr. Andrew Cheung, 
General Manager.  Mr. Cheung provided background 
on Tegent. Consistent with the information noted 
above, Mr. Cheung stated that Tegent has been in 
business since approximately 1993.  It sells 
primarily U.S. and European-made instruments to 
the Hong Kong and mainland China markets with 
approximately USD 30 million in annual turnover. 
It has approximately 150 staff in Hong Kong and 
mainland China.  Agilent is a major supplier to 
Tegent of lab instruments and chemical analysis 
machines.  According to Mr. Cheung, typical uses 
for these instruments include testing for 
pesticide and antibiotics residue in foodstuffs as 
well as pollution testing. 
 
¶5.  Mr. Cheung was familiar with export controls 
noting that his company encounters the export 
control requirements of the United States, Hong 
Kong and Japan (for certain Agilent products 
sourced from Japan).  As to U.S. export controls, 
Mr. Cheung stated that he relies primarily on 
Agilent to take care of these formalities as it is 
quite familiar with U.S. export control rules. 
The ECO provided Mr. Cheung with information on 
U.S. reexport controls (BIS publication 'Guidance 
on the Department of Commerce's Reexport 
Controls'). 
 
¶6.  With respect to the shipment that was the 
subject of the PSV, Mr. Cheung provided an 
original purchase order reflecting that the items 
were sold to Yunnan Tea Garden Group of Kunming, 
China.  Mr. Cheung stated that the items had not 
yet been shipped to the customer and were 
available for ECO's inspection in the company's 
warehouse in the same building.  Mr. Cheung 
subsequently corrected himself and stated that the 
items were located at another location awaiting 
shipment.  He offered to have them delivered from 
the offsite location to the company for 
inspection.  On March 29, 2007, ECO and Commercial 
Assistant Lai visited Tegent and were able to 
inspect Agilent shipping boxes with the units 
 
 
inside. 
 
¶7. At the time visited, Tegent appeared to be a 
suitable recipient of the commodities shipped (as 
reseller) since Tegent cooperated with the PSV and 
provided all requested information concerning the 
final disposition of the applicable items.  The 
ECO recommends that this PSV be classified as 
Favorable. 
Cunningham