Heidelberg Instruments response
...Our products are not listed in the Annexes of the EU Regulation 2021/821. None of our systems is listed in the national Export Control Lists.
For all our systems we are in possession of current “AzG”s – “Auskunft zur Güterliste”. That is an official statement issued by the BAFA (Federal Office for Economic Affairs and Export Control) for each of our products, confirming that these do not fall within the range of goods listed in the Annex I of EU Regulation 2021/821 or in Part I of the national Export Control List (Annex AL of AWV (German Export Regulations)), nor under EU Anti-Torture Regulation 2019/125 or EU Firearms Regulation 258/2012.
Our products therefore do not require official export approval or export licenses. We also carry out strict export control checks in-house routinely as part of our processes...
At the start of the Russian war of aggression towards Ukraine on 22 February 2022, we have immediately ceased all remaining business interactions with Russia and Belarus, including sales and service. We categorically adhere to the EU Regulation 2022/328 of 25 February 2022, which supplements the EU Regulation 833/2014 and which in Article 2a (1) prohibits the sale of all technology (which is listed in Annex VII and specifies laser lithography systems amongst others) which might contribute to Russia’s military enhancement. We have not had any business interactions with anyone in Russia since the begin of Russia’s war against Ukraine.
We take utmost care to thwart any attempts by prospective customers to circumvent the sanctions. We have to this aim introduced additional checks into our in-house export controls and we cooperate very closely with the BAFA (Federal Office for Economic Affairs and Export Control) and the Verfassungsschutz (German Domestic Intelligence Services) at all times...
The product type in question, the laser lithography system DWL 66 FS, was introduced in 2006 as the successor to a previous similar system. The product during its lifetime received continued improvements but around 2013, it was discontinued and succeeded by a major new release, the DWL 66+, a product that also continues to be updated regularly. The DWL 66 FS therefore has not been part of the Heidelberg Instruments product portfolio for more than 10 years and its level of technology has long since been exceeded.
In addition, as neither qualified service nor the highly specialized spare parts have been available to Russian users in the past three years, it is highly unlikely that this DWL 66 FS system is still in a position to operate to original specifications, or even to function in a useful way at all. It is both an outdated and complex system and will, without proper maintenance, become completely inoperative at some point if it has not already done so.
