THE LEGAL FRAMEWORK GOVERNING NUCLEAR EXPORT CONTROL SYSTEMS
Authored By- Kabir Kapoor
Second Year, BLS LLB
Rizvi Law College
Nuclear energy has come to the forefront in the 21st century, and with it, the development of nuclear technology and trade as well. Some countries engage in it for peaceful and scientific purposes and some for a more hostile agenda. Thus, it is extremely important to have control systems in place regarding the export and import of nuclear technology and laws that prevent its harmful use. While there already exists rules about this in place, their authority and legality is murky at times with overlapping jurisdiction, ambiguities present in the laws as well as a few key issues not being highlighted as much as they need to. This paper aims to study the workings of the existing systems in place, the challenges being faced, and analyse the loopholes and proposed solutions put forth by the international community.
1.0 Nuclear Law
1.1 Definition of Nuclear Law
“The body of special legal norms created to regulate the conduct of legal or natural persons engaged in activities related to fissionable materials, ionizing radiation and exposure to natural sources of radiation.”
This definition comprises four key elements. First, as a body of special legal norms, nuclear law is recognized as a part of general national legislation, while at the same time comprising different rules required by the special nature of the technology. Second, the element of regulation incorporates the risk–benefit approach that is central to managing activities that present both hazards and advantages for social and economic development. Third, as with all legal regimes, the special legal norms relate to the conduct of legal persons, including commercial, academic, scientific and governmental entities, as well as of individuals. The fourth element focuses on radioactivity (produced through the use of fissionable material or ionizing radiation) as the defining feature justifying a special legal regime.
1.2 Objective of Nuclear Law
The primary objective of nuclear law is: “To provide a legal framework for conducting activities related to nuclear energy and ionizing radiation in a manner which adequately protects individuals, property and the environment.”
In light of this objective, it is particularly important that responsible authorities carefully assess their current nuclear energy activities and their plans for future nuclear energy development so that the legislation ultimately adopted is adequate.
2.0 Nuclear Trade
The rules of trade are those of treaties, laws, agreements, and regulations pertaining to international transfers of nuclear material, equipment, technology, or personnel. These rules are needed to keep countries assured that international trade in nuclear energy will not facilitate the manufacture of nuclear weapons. Trade in Nuclear Energy is a rather sensitive affair. Any country that possesses the power of Nuclear Energy automatically is deemed with a position of power and has a strong diplomatic hand during discussions. Hence, countries that possess Nuclear Energy aren’t keen to let it spread to other countries and other countries (that don’t possess Nuclear Energy) are very willing to acquire the same.
3.0 Nuclear Suppliers Group and the Trigger List
The Nuclear Suppliers Group (NSG) is a transnational body that comprises nuclear supplier countries that aim to control the proliferation of nuclear weapons by curbing the export of nuclear weapons, development materials and related technology. The main objective of NSG is to improve upon the existing safeguards on current nuclear materials. It was formed in 1974 by seven countries (Canada, West Germany, France, Japan, the Soviet Union, the United Kingdom, and the United States). When it was recognised that the Non- Proliferation Treaty alone could not halt the spread of nuclear weapons, a multilateral nuclear export control arrangement was formed.
3.1 Guidelines for Nuclear Transfer
For any non-nuclear weapon state and, in the case of controls on retransfers, to transfers to any State, the fundamental safeguards and export control principles are applicable to nuclear transfers made for peaceful purposes. The so-called ‘Trigger List’ has been defined by providers in this context. Guidelines for nuclear transfers are included in the list, along with supporting activities like physical protection, safeguards, specialised controls on sensitive exports, special arrangements for the export of enrichment facilities, controls on material usable for nuclear weapons, controls on retransfers, and others.
Annex A includes material and equipment along with other technology associated with each of the items on the trigger list. Annex B includes clarification of items on the trigger list. Annex C deals with the criteria for levels of physical protection. The second set of NSG Guidelines governs the export of nuclear-related dual-use items and technologies, that is, items that can make a major contribution to an un-safeguarded nuclear fuel cycle or nuclear explosive activity, that simultaneously has non-nuclear uses as well, for example in the industry. Guidelines for the transfer of dual-use goods are also included, which are listed in different categories.
3.2 Country Specific Export Controls
The NSG Guidelines are applied to all nuclear transfers and the group has not developed country-specific controls. However, the NSG has recently made public statements about nuclear programmes and activities of concern in specific countries. This could be interpreted as a signal that country-specific controls might be the next step for the NSG. After North Korea carried out a nuclear weapon test in 2006 the UN Security Council unanimously adopted Resolution 1718. This resolution included provisions to prevent the transfer of nuclear technology to North Korea. The resolution also authorized the inspection of cargo to ensure compliance with the measures adopted. The Security Council decided that all UN member states ‘shall prevent the direct or indirect supply, sale or transfer to the DPRK, through their territories or by their nationals, or using their flag vessels or aircraft, and whether or not originating in their territories’ of items specified in several lists that form part of the resolution.
One of these lists is UN document S/2006/814, which is a list of nuclear material, equipment and technology as well as nuclear related dual-use equipment, materials, software and related technology. It is clear that the list is closely modelled on the control lists developed by the NSG. This development, along with the adoption of similar measures related to Iran’s nuclear programme, should logically require the NSG to develop specific arrangements to help implement and enforce the relevant resolutions. It is of primary importance that NSG participating states are themselves able to implement UN decisions effectively. However, given the growing focus on export control outreach in recent years, the NSG could also consider what can be done to help non-participating states to meet their obligations to the United Nations when the Security Council adopts country specific measures.
3.3 India’s System and the Guidelines of the Nuclear Suppliers Group
India’s legislation dealing with “Weapons of Mass Destruction and Their Delivery Systems” states that the Act is meant "to prohibit unlawful activities in relation to weapons of mass destruction (WMDs), their means of delivery and related dual-use materials, equipment and technologies." An analysis of India’s nuclear control list (category 0 in the SCOMET list) has identified that India’s list controls equipment that has been “specially designed, prepared, or adapted or used or intended to be used” in nuclear systems. Thus, the SCOMET list in its definition of usability covers dual-use items, that is, items that can be used for a nuclear purpose but that need not have been specially designed for that purpose.
The language in India’s nuclear control list, therefore, does restrict dual-use materials, equipment and technologies, and is in accordance with the WMD related Act passed in 2005, as well as India’s commitments to the US to have its export controls in accordance with the NSG guidelines.
3.4 Workings of the International Atomic Energy Agency (IAEA)
According to IAEA, “The IAEA is the world's centre for cooperation in the nuclear field. It was set up as the world's "Atoms for Peace" organisation in 1957 within the United Nations family. The Agency works with its Member States and multiple partners worldwide to promote the safe, secure, and peaceful use of nuclear technologies.” Applying, under the Nuclear Non- Proliferation Treaty (NPT) and other international treaties, mandatory comprehensive safeguards in non- nuclear-weapon states (NNWS) parties to such treaties.
Article III.A. 5 of the IAEA Statute authorizes the Agency "to establish and administer safeguards designed to ensure that special fissionable and other materials, services, equipment, facilities and information made available by the Agency or at its request or under its supervision or control are not used in such a way as to further any military purpose, and to apply safeguards, at the request of the Parties, to any bilateral or multilateral arrangement, or at the request of a State, to any of the State's activities in the field of atomic energy. " The Agency's safeguards system was thus conceived as a legally binding scheme of verification for all IAEA-related nuclear transactions which would apply when a State received assistance from or through the IAEA under an Agency project. Nuclear activities in which the IAEA was not involved would be subject to safeguards only on a voluntary and selective basis.
During the 1970s, the IAEA’s safeguards system underwent a major transformation in character and scope. The change was the result of the development of what is referred to as the "non-proliferation regime"; that is the set of legal norms and voluntary undertakings which were developed both within and outside of the framework of the IAEA to deal with the peaceful uses of nuclear energy and nuclear weapons proliferation.
Of wider significance is the 1968 NPT, which is of a universal character. It provides that each non-nuclear-weapon State party to the Treaty assumes a basic obligation not to manufacture, acquire, receive or control nuclear weapons or other nuclear explosive devices. In addition, such a State agrees to accept the safeguards set forth in an agreement to be negotiated and concluded with the IAEA in accordance with the latter Statute and its safeguards system. The exclusive purpose of this agreement is the verification of the fulfilment by the State of its treaty obligation to prevent the diversion of nuclear energy uses to nuclear weapons or other nuclear explosive devices. Thus, for States parties to these agreements, acceptance of IAEA safeguards that are comprehensive in scope has become obligatory in character.
3.5 The Role of Private Companies
Private corporations have been a part of the nuclear technology sector since the Manhattan Project. The process of harnessing nuclear energy has many components which require specialised technologies and knowledge. It also requires a high degree of safety due to the presence of ionising radiation. Private corporations also need to adhere to the regulations of individual countries such as the USA’s Nuclear Regulatory Commission (NRC) and India’s Atomic Energy Regulatory Board (AERB).
4.0 Conventions and Committees
4.1 The Nuclear Non- Proliferation Treaty (NPT)
The Nuclear Non-Proliferation Treaty. NPT is an international Treaty that is characterised by three pillars:
The NPT bifurcates its signatories into two categories- Nuclear Weapon States (NWS) and Non-Nuclear Weapon States (NNWS). NWS are states that detonated a nuclear explosion before 1st January 1967 i.e. UK, US, USSR, France, and China, while NNWS comprise of the rest. NNWS states agree to not acquire nuclear weapons by any means while NWS agree to aim for disarmament. Since its first signing, all but 5 member nations of the UN are Parties to the treaty. India, Pakistan, Israel and South Sudan never signed the Treaty while DPRK withdrew from it.
4.2 The Zangger Committee (ZAC)
Article III of the NPT states that all Parties agree to the comprehensive safeguards and standards set forth by the IAEA and about its distribution. Article III, paragraph 2 specifically talks about - “Each State Party to the Treaty undertakes not to provide: (a) source or special fissionable material, or (b) equipment or material especially designed or prepared for the processing, use or production of special fissionable material, to any non-nuclear- weapon State for peaceful purposes, unless the source or special fissionable material shall be subject to the safeguards required by this Article”
The ZAC was formed to interpret and fulfil this obligation. Its primary focus being the interpretation of Art. III.2, specifically states “especially designed or prepared equipment or material for the processing, use or production of special fissionable material.” It aims to prevent nuclear exports, whose purpose is for peaceful use, from being used for nuclear weapons. Their main work relies on the restriction of certain nuclear materials and equipment from Parties to the Treaty to any NNWS unless the export is sanctioned by any IAEA safeguard.
4.3 United Nations Platform of Nuclear Weapons Free Zone
Article VII of the NPT states that- “Nothing in this Treaty affects the right of any group of States to conclude regional treaties in order to assure the total absence of nuclear weapons in their respective territories”. Most treaties that deal in this domain come under the common umbrella of the United Nations Platform for Nuclear- Weapon-Free Zones. Their objectives are the same as that of NPT but function differently. As defined by the General Assembly Resolution 3472 (XXX) B (1975), a Nuclear-Weapon-Free Zone is any region, composed of UN-recognised member states, with the total absence of nuclear weapons and an international system of verification and control to check compliance of the treaty.
5.0 Export Control Regimes
The Nuclear Suppliers Collection (NSG) is a group of nuclear supplier nations that aims to prevent the spread of nuclear weapons by putting two sets of export guidelines for nuclear and nuclear- related goods into effect. The Non-Proliferation Principle seeks to cover the rare but important cases where adherence to the NPT or a nuclear weapon Free Zone Treaty may not by itself be a guarantee that a State will consistently share the objectives of the Treaty or that it will remain in compliance with its Treaty obligations.
5.2 The Wassenaar Arrangement
The Wassenaar Agreement on Export Controls for Conventional Arms and Dual-use Goods and Technology is one of four multilateral export control regimes in which various countries participated. This agreement aims to promote transparency and accountability in the transfer of conventional weapons and dual-use (i.e., civil and military) materials and technologies, and to prevent the precarious accumulation of these materials, thereby contributing to regional and international security and stability. Member governments shall enact these controls to ensure that transfers of controlled items do not contribute to the development or strengthening of military capabilities that undermine the objectives of the Agreement and are not diverted to support such capabilities carry out. In addition, the Wassenaar Arrangement imposes a number of reporting obligations on member governments.
5.3 Australia Group
The Australian Group (AG) was formed in 1985 following Iraq's use of chemical weapons in the Iran-Iraq War (1980-1988). Australia is concerned about the development of chemical weapons in Iraq and recommended harmonisation of international export controls on chemical weapons precursors. As the AG's membership increased, emphasis was placed on chemical production facilities, techniques and measures to prevent the spread of biological weapons. Today the AG is made up of 42 Member States.
5.4 Missile Technology Control Regime
The Missile Technology Control Regime (MTCR) is an informal coalition of nations working to prevent the proliferation of unmanned weapon systems capable of delivering weapons of mass destruction (WMD). Members of the Missile Technology Control Regime (MTCR) (referred to as `partners') are also seeking coordination of national laws regarding the licensing of such systems for export to other countries. As a result, MTCR's membership and focus have expanded. To overcome these difficulties, all MTCR members and some non-Members have established standards to be used to control the export of certain goods, materials, technology and software, voluntarily introduced missiles and missile export licensing measures.
6.0 Case Study
6.1 Iran Nuclear Deal
The Iran nuclear agreement formally known as Joint Comprehensive Plan of Action (JCPOA), was a landmark agreement reached between Iran and several world powers including China, France Russia, The United Kingdom, and The United States. According to the deal, Iran agreed to dismantle much of its nuclear program and open its facilities to international inspections in exchange for billions of dollars’ worth of sanction relief.
Going into the negotiations the U.S. estimated that Iran could produce enough nuclear material to build a weapon. The member nations feared that Iran’s move to become a nuclear weapons state risked propelling the region into crisis. Israel had already taken action against suspected nuclear facilities in Iraq and Syria and would most probably do the same against Iran, triggering disruptions to the transport of oil in the Persian Gulf. Saudi Arabia had also expressed their willingness to obtain a nuclear weapon if Iran detonated one.
Iran agreed not to produce either the highly enriched uranium or the plutonium that is used in nuclear weapons. Iran also agreed to implement a decorum to allow inspection from the International Atomic Energy Agency (IAEA) and the United Nations nuclear watchdog. The EU, the UN and the United States agreed to lift the UN ban on Iran’s transfer of conventional weapons and ballistic missiles after five years if the IAEA certifies that Iran is only engaged in civilian nuclear activity. However, in 2018, the US withdrew from the agreement and reinstated the sanctions. [RS1] In response to these actions Iran started exceeding agreed-upon limits to its stockpile of low-enriched uranium in 2019. The EU has also imposed several sanctions on Iran which include restrictions in the financial sector by freezing the assets of the Central Bank of Iran.
Even after the completion of the initial phase of the JCPOA, the deal stalled immensely due to USA backing away from it citing reasons of security and the lack of trust in Iran and Iran’s government not compromising further, efforts to renegotiate or restart the deal have been moot over the past years with the US having a change in administration or Tehran becoming more hostile towards the West. Recently Iran maintained that it has no interest in increasing its Uranium enrichment levels but the Director General of the IAEA has raised alarms with respect to the country’s position and it seems the tensions shall continue.
7.0 Analysis of the Legalities
The previous section concluded that certain necessary elements of modern and effective export control legislation have been agreed on a widespread if not fully global basis. However, the specific way in which these agreed elements are reflected in national law is different in different countries. The same can be said for the administrative system which is needed to license exports in order to implement the laws. Although there are many diverse approaches to organizing export licensing, there is emerging agreement on the tasks that need to be performed if licensing is to be efficient and effective. The same conclusion cannot be reached regarding to the enforcement of export controls. Advancing this dialogue should become a high priority for the NSG in the near future.
7.1 Enforcing Nuclear Export Controls
The above sections present the conclusion that the NSG has made a significant contribution to strengthening export control. However, it can also be concluded that there are still many challenges to overcome.
Clandestine nuclear trafficking is now known to have contributed significantly to illegal weapon programmes in at least three countries—Iraq, Libya and North Korea. Several other countries (including Iran and Pakistan) have also drawn on illicit trafficking networks to acquire items for their nuclear programmes. In a number of these cases it is now known that items were acquired from countries that participate in the Nuclear Suppliers Group. The checking and assessment that forms part of the licensing process can be considered one form of enforcement. However, the evidence of significant export control failures leads to the conclusion that licensing needs to be supplemented by other measures. The screening of information presented by exporters to customs authorities could become an important element of export control enforcement through initiatives intended to strengthen security in the supply chain, such as the 2005 Framework of Standards to Secure and Facilitate Global Trade (SAFE) being developed in the World Customs Organization and adopted by its members.
These initiatives require exporters to submit information to customs authorities before goods arrive at the border prior to leaving the jurisdiction of the export control authorities. The Framework of Standards also requires that this information must be in electronic form. This allows specialists to examine the electronic data and compare it with risk indicators in an effort to uncover the unlicensed export of controlled items. Developing closer cooperation with exporters is an aspect of preventive enforcement that is beginning to attract increased attention from export control authorities. However, working more closely with industry is another area where the NSG could strengthen its efforts. The task of outreach to industry is mainly the responsibility of national export control authorities. However, the NSG should engage more strongly in discussing and reporting on national outreach programmes. As an example, the EU internal review of how member states implement dual-use export controls revealed significant differences in national approaches to export control outreach to industry.
The NSG could usefully discuss the elements of national outreach programmes as well as the methodologies, materials and events that have proved to be effective in this area with a view to improving the quality of outreach efforts. Since 1997 the NSG has organized two international seminars on the role of export controls in nuclear non-proliferation. Although representatives from the industry were invited to participate on both occasions, these seminars did not address the role of industry in export control enforcement or collect the views of exporters about export control on a systematic basis. There is a strong case for seminars to interact with nuclear industry associations such as the European Atomic Forum (FORATOM).
In particular, dialogue with industry will be vital in attempting to modernize export controls to cope with developments such as the transfer of technology using intangible means and the increasingly international ownership structure of the global nuclear industry. Investigating, prosecuting and punishing violations of relevant laws represent another important element of export control enforcement. Some nuclear traffickers have been convicted of various export related offences in the recent past.
It is the responsibility of states to task law enforcement authorities with responsibility for investigation and prosecution and to provide adequate resources and training for enforcement officers. However, there could be a role for the NSG in facilitating effective investigations and prosecutions. States must ensure that the frameworks for cooperation between relevant agencies outside the country are in place so that they can be available when needed to gather information and evidence. States must also establish effective penalties, (which may include criminal sanctions, civil fines, publicity and restriction or denial of export privileges) sufficient to deter violations of export controls. The question of what kind of penalties provide an effective deterrent as well as an appropriate punishment for different offences should also be discussed internationally.
Establishing special rules to govern licensing of the most proliferation-sensitive technologies is also under discussion within the NSG. However, it may not be possible to reach an agreement over the further restrictions on the supply of sensitive technologies while the future role of nuclear power in the energy strategies of many states is undecided. The development of effective nuclear non-proliferation policies requires that the process of planning the role of nuclear power in future energy strategies is completed in the shortest possible time.
One important issue that should form part of the wider discussion of nuclear non-proliferation is the future role of multinational ownership and management of nuclear facilities, in particular the most sensitive facilities, in relation to the conditions for nuclear supply. In 2004 the Independent Expert Group on Multilateral Approaches to the Nuclear Fuel Cycle, commissioned by the Director General of the IAEA, completed its work, which was published in early 2005. The subsequent discussion of the options laid out by the expert group among IAEA member states has been rather slow.
Recent discussions under the umbrella of the IAEA have suggested that a comprehensive multilateral system could be achieved but only in the medium to long term. However, this discussion took place at a special event organized by the IAEA Director General on the side-lines of the IAEA General Conference to examine a New Framework for the Utilization of Nuclear Energy in the 21st Century. It can be concluded that the adoption of conditions of supply linked to multilateral ownership and control is also likely to lie some way in the future.
7.2 A Global Framework Regulating Nuclear Supply
Since the early 1990s the UN Security Council has progressively taken closer and closer interest in preventing nuclear proliferation, which was identified as a threat to international peace and security in a joint statement by the heads of state and government of the countries serving on the Security Council in 1992. However, this joint statement has not been translated into a legal form that could create a global nuclear non-proliferation framework. Therefore, it is still the NPT that provides the closest approximation of a global legal framework for non-proliferation. While the NPT has near-universal participation, a growing number of questions are being asked about whether it can continue to provide a global framework for non-proliferation efforts. It has not been possible to adapt the NPT, although the conditions in the global nuclear industry have changed fundamentally since the 1960s, when the treaty was negotiated. Geopolitical and strategic conditions have also changed fundamentally since the 1960s in ways that have a direct bearing on issues that are central to the objectives of the treaty. In particular, the role that nuclear weapons played in the strategies of the recognized nuclear weapon states has changed since the end of the cold war. The changed conditions, in the nuclear industry in particular, create challenges for export control.
The number of nuclear suppliers has increased and the places where those suppliers are to be found are no longer concentrated in the countries that have been traditional partners in export control cooperation. The number of countries operating significant nuclear facilities is also expected to grow, as are the number of facilities being operated in countries that already have a nuclear infrastructure in place which will multiply the number of nuclear end-users and the scale of international nuclear trade (including services that facilitate trade such as freight forwarders and companies that specialize in helping exporters prepare and submit export documents).The nuclear industry is no longer ‘stove piped’ within countries, and a business model based on international cooperation is becoming more common. Research and development is already being carried out by multinational companies on a global scale, involving laboratories and facilities in different countries. As noted above, it is highly unlikely that these standards could be developed within the NPT. However, by linking activities carried out in its different constituent parts, the UN might provide a global framework for developing and approving the necessary standards.
Recent proposals could form the basis on which a global export control framework might develop, by linking actions taken in different parts of the UN in a coherent manner. The main problem as is prevalent with most international treaties is the juxtaposition between international law and a country’s respective national law and since the latter supersedes the former, it makes it easier to violate these conventions under the guise of defences like “national interests” or “threats to security” and more importantly there exists loopholes and hypocrisies within those very treaties as well which makes their interpretation and enforcement by bodies tougher unless they have universal jurisdiction. An important agenda like nuclear trade begs for an airtight set of regulations that is not “one size fits all” in nature but which takes into consideration the geopolitics of different regions and the nuances of nuclear and non-nuclear states in the world.
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[RS1]Can’t find the source for footnote no.21, the link does not direct to the page.