...We wish to provide clarification as to why LINAK should be removed from the list in Appendix 4:

In Q1 2024, the Danish Business Authority engaged LINAK in a dialogue regarding a LINAK product (#121000-11302420, referred to as “the Product”) reportedly found on a battlefield as it was featured in 'Foreign components in weapons' at nazk.gov.ua, published at that time.

However, the case was not a violation of the sanctions and LINAK has therefore submitted a reply to the Danish Business Authority in which we argue that the case should be waived. Our position is based on the following facts and argumentation:

• The label, photographed and featured in 'Foreign components in weapons' at nazk.gov.ua, indicated the manufacture date was April 18, 2020. Based on the information we have, it is apparent that this product was legitimately sold well in advance of the Russian invasion of Ukraine on February 24, 2022, and long before the European Union's 11th sanctions package implemented June 2023 which sanctioned the item for export to Russia.
• LINAK ceased all sales to Russia from February 2022 following the invasion of Ukraine. This cessation applied to both LINAK's subsidiary in Russia and our local distributor.
• The part number in question is a generic LINAK actuator, which is used in a wide range of applications and for many different purposes, ranging from hospital beds to agricultural machinery.
• The product is not subject to export controls under Regulation 2021/821 Annex I – (“the Control List”), as it is not a dual-use article. In this regard, LINAK has carried out a systematic review of its products and compared them with the specifications in the Control List to identify possible dual-use products.
• HS 850131 and thus the Product is also not listed in Annex VII to Regulation 2014/833, which is believed to be one of the more critical annexes to Regulation 2014/833, as it contains products and technology that can contribute to Russia's military and technological improvements or to the development of the defense and security sector.
• • HS 850131 does not appear on the high-priority list of 50 HS codes introduced by the EU and its allies. This list refers to the articles found in Russian weapons on the battlefield in Ukraine. HS 850131 and thus the Product has not been subject to export restrictions to Russia until 23 June 2023 (11th sanctions package). With the 11th sanctions package, it was listed on Annex XXIII, which is made to broadly limit Russia's industrial capacity and thus Russian economy.
• As mentioned above, LINAK has in general stopped the sales to Russia long before LINAK was legally obliged to stop certain sales to Russia. LINAK makes great efforts to prevent the product from finding its way to manufacturers of weapons equipment used by the Russian military.
• LINAK conducts a comprehensive screening. During initial discussions with a potential customer, the potential customer is created in LINAK's database. For suppliers, a screening takes place before the supplier is created by LINAK. Both potential and existing customers as well as suppliers are continuously (daily) screened in Thomson Reuters OneSource. Thomson Reuters screening tool is one of the most advanced on the market, and contains large amounts of data on ownership, so there is a so-called hit if a listed entity has an ownership interest of 10% or more. LINAK has invested in this system in order not to enter indirect trade with sanctioned entities, i.e. natural or legal persons, entities or bodies owned or controlled directly or indirectly by natural or legal persons, entities or bodies covered by Annex 1 of Regulation 269/2014. We trust that this clarifies our position that LINAK should be removed with immediate effect from the list in Appendix 4 of the Report...