Japan-South Korean Trade Tensions:
Implications for Technology Supply Chains
- On July 1, Japan’s Ministry of Economy, Trade and Industry (METI) announced that export control regulations would be placed on three high-tech chemical materials, considered essential for semiconductor and microchip production, effective from July 4. Japan has also announced on August 2 that it will be removing South Korea from a preferential ‘whitelist’ that will result in additional customs clearance measures for 40 categories of products that could have sensitive military applications.
- Japan’s export control restrictions on hydrogen fluoride, photoresists, and fluorinated polyimide threaten to disrupt integrated supply chain networks between Japanese high-tech chemical suppliers and South Korean semiconductor manufacturers. South Korean technology giants Samsung Electronics, SK Hynix, and LG Display as well as Japanese chemical suppliers Stella Chemifa (supplying hydrogen fluoride), Tokyo Ohka Kogyo Company Ltd. (supplying photoresists), JSR Corporation (supplying photoresists), Ube Industries Ltd. (supplying fluorinated polyimide) and Kaneka Corporation (supplying fluorinated polyimide) are currently the most impacted firms.
- Japan’s decision to remove South Korea from its preferential trade white list will result in additional export and customs clearance restrictions as Japanese exporters will now need individual authorization approval for exports. Up to 40 product categories will be impacted which include titanium alloys, carbon fiber, generators, gyroscopes, crane trucks, isotactic presses, frequency changers, pressure transducers, and milling machines. The measures will come into effect on August 28. In response, South Korea on August 12 announced plans to drop Japan from its own preferential ‘whitelist’ and to place the country in a newly created trade category of countries that have not kept its export control system in line with international export control principles.
- The latest trade dispute between Japan and South Korea over export control regulations is already affecting global tech supply chains. Although most global tech manufacturers will be able to cope with a temporary drop in memory chip production for smartphones and computer servers, a prolonged stalemate may force some companies to come up with contingency plans to combat supply shortages and higher prices.
On July 1, Japan’s Ministry of Economy, Trade and Industry (METI) announced two major amendments to its export control regulations in relation to South Korea that could have significant impact on global tech supply chains.
Effective since July 4, Japanese exporters are now required to apply for individual export licenses for three high-tech chemical materials – fluorinated polyimide, photoresists, and hydrogen fluoride (also known as etching gas) and their relevant technologies – that are widely considered to be essential for semiconductors and their components, such as memory chips, microprocessors, and integrated circuits. Japanese suppliers will be required to apply for individual export licenses to export the materials to South Korea with an inspection process that is expected to take about 90 days. The move has been regarded as a direct threat to South Korea’s semiconductor industry that is heavily reliant on Japan for high-tech chemical materials that are critical for producing electronic goods such as electronic displays, smartphones, and other devices.
This has been followed by Japan’s decision on August 2 to remove South Korea from its preferential trade ‘whitelist’ of 27 countries that enforced minimal constraints on the export of Japanese-made goods with sensitive military applications. Although not an outright ban, South Korea will likely face significant delays and disruptions to imports from Japan as Japanese exporters will need individual authorization instead of a fast-track approval. South Korea is the first country to be removed from the white list and the removal will come into effect on August 28, 2019. The move will impact 40 product categories of Japanese import which include precision machinery tools, manufacturing and engineering equipment, lithium-ion batteries, and carbon fiber.
South Korea, in retaliation, also announced plans on August 12 to remove Japan from its fast track ‘whitelist’ country status by downgrading it into a new category in September. Further details, including the proposed effective date, are yet to be determined. According to South Korea’s Trade, Industry and Energy Ministry, about 1,735 strategic products and materials that include military applications exported to Japan may need to undergo tighter regulation process. South Korean companies exporting to Japan will therefore need to submit two additional documents compared to the three documents required today. Moreover, application processing time may take up to 15 days, which is an increase from the current 5-day period. According to reports, the materials can be used in chip making machinery, network security equipment, and telecommunications gear.
The trade dispute dates back to October 2018 when the South Korean Supreme Court ordered Japanese steelmaker Nippon Steel to compensate four South Korean plaintiffs KRW 1 million (USD 87,700; EUR 77,110) for forced-labor practices during Japanese colonial rule from 1910-1945. Japan has rejected these rulings and insists that the issue was already settled as part of the Treaty of Basic Relations signed in 1965 by the two countries. Moreover, Tokyo has accused Seoul of lacking proper monitoring of exported sensitive materials with Japan suggesting that etching gas – which can also be used for producing nuclear and chemical weapons – was illegally shipped to Vietnam in December 2017 and the United Arab Emirates in January 2019.
|October 30, 2018||South Korean Supreme Court rules that Japanese steelmaker Nippon Steel must compensate South Korean victims for forced-labor practices during Japanese colonial rule from 1910-1945.|
|July 1, 2019||Japan’s Ministry of Economy, Trade and Industry (METI) announces it will adopt export controls to South Korea of three high-tech chemical materials used in semiconductor and smartphone products. METI simultaneously contemplates whether to remove Seoul from a 27-country preferential export whitelist.|
|July 3, 2019||South Korea pledges to invest KRW 1 trillion (USD 854.4 million; EUR 757.8 million) to produce home-grown materials and semiconductor equipment to reduce reliance on Japanese suppliers.|
|July 4, 2019||Japan’s export controls on high-tech materials to South Korea come into effect.|
|July 5, 2019||South Korean consumer boycotts emerge in response to Japanese export curbs.|
|July 12, 2019||Japanese and South Korean officials meet to discuss export control restrictions. No resolution comes out of the meeting.|
|July 24, 2019||South Korea raises Japanese export control restrictions as a formal agenda item at the World Trade Organization General Council meeting. Deadline for canvassing public comments on whether Japan’s METI should remove South Korea from preferential whitelist. South Korea submits official letter requesting that Japan does not remove the country from preferential whitelist.|
|August 2, 2019||Japan officially removes South Korea from preferential whitelist.|
|August 8, 2019||Japan allows first export of high-tech materials since export controls came into effect.|
|August 12, 2019||South Korea announces plans to drop Japan from its own trade whitelist as a retaliatory measure against Japan.|
|August 13, 2019||South Korea considers adopting export controls on dynamic random access memory (DRAM) chips to Japan.|
|August 28, 2019||Removal of South Korea from Japan’s preferential whitelist to come into effect.|
Japanese Export Controls on High-Tech Materials
Japan’s market dominance in high-tech chemical materials like fluorinated polyimide, photoresists, and etching gas has meant that South Korean chipmakers are finding it difficult to secure alternative sources of supply. Japan produces 90 percent of fluorinated polyimide and about 70 percent of etching gas in the world, as well as 90 percent of photoresists. According to Korean industry data, Japan accounted for 94 percent of South Korea’s fluorinated polyimide imports, 44 percent of its etching gas, and 92 percent of its photoresist supplies from January to May 2019.
Fluorinated polyimide is a synthetic resin that is used as a substrate in flexible organic light-emitting-diode screens and can be used for smartphone displays and other components. Photoresists are thin layers of material used to transfer circuit patterns onto semiconductor wafers. Hydrogen fluoride is a colorless gas or liquid used as a ‘wet’ etching gas that is mainly for cleaning wafers during the chip making process. Before etching begins, the wafers are coated with photoresist and exposed to a circuit pattern during photolithography. Patterning and etching are then repeated multiple times throughout the chip making process.
Table 2 outlines suppliers based in Japan and South Korea providing these high-tech materials and the products they are used in.
|Fluorinated polyimide||Ube Industries Ltd., Kaneka Corporation||Smartphone displays and other components. Used in high temperature fuel cells, displays, and various military roles.|
|Photoresists||Tokyo Ohka Kogyo Shin-Etsu Chemical, JSR Corporation||Semiconductor wafers. Used in microelectronics and microsystems technologies.|
|Hydrogen fluoride (etching gas)||Stella Chemifa, Morita Chemical, Showa Denko, Foosung Company||Removes excess material from circuit patterns for silicon wafers. Raw material used in manufacturing of refrigerants, gasoline, and aluminum.|
For Japanese suppliers, the export restrictions have brought about uncertainty, as exporters will need to apply for a permit for each batch of shipments sent to South Korea that will be subject to inspection, which could take up to 90-days. Stella Chemifa Corporation, which controls up to 70 percent of the market for high-purity hydrogen fluoride, declined to reveal to what extent its South Korean joint venture could meet client demands for the material. Photoresists supplier Tokyo Ohka Kogyo Company Ltd. has a plant in South Korea but will have to source some materials from Japan to produce photoresists, meaning that the export restrictions could slow down supplies once existing inventories are depleted. JSR Corporation has also confirmed that it could supply some photoresists from its Belgian plant. Japanese fluorochemicals maker Kanto Dengka Kogyo is also expected to be impacted. Meanwhile, Morita Chemical Industries is reportedly finding ways via a third country to avoid export controls. Through a joint venture with China, the firm plans to produce ultrapure hydrogen fluoride in China to sell it both to the Chinese market as well as to Samsung production units in China, and possibly ship it to South Korea.
South Korean technology giants Samsung Electronics and SK Hynix are the most heavily impacted by the new restrictions with the export curbs also affecting LG Display. Although the company managed to secure emergency supplies for the three key materials, Samsung has already sent a letter to its suppliers to purchase three months of Japanese components, with the company reportedly pledging to provide financial aid for procurement, as it prepares for contingency plans to cope with the prospect of extended supply shortages. In terms of the high-tech chemical materials, the export curbs on photoresists will likely impact Samsung’s efforts to produce chips based on an advanced technique known as extreme ultraviolet (EUV) lithography as it seeks to keep pace with industry competitor Taiwan Semiconductor Manufacturing Company Ltd. (TSMC). The company is also contemplating rolling back plans to release its most advanced processor chip, 7-nanometer chips, by early 2020 due to the uncertainty brought on by tighter export controls.
SK Hynix, the second largest manufacturer of dynamic random access memory (DRAM) chip, does not have three months of inventory and may be forced to halt production if it cannot procure the necessary materials from Japan. The company has already announced that it is lowering its production capacity for DRAM chips for the fourth quarter of 2019 and lowering its NAND flash wafer input by more than 15 percent from the previous year. It is also planning to transfer some of the production lines at its Incheon factory to semiconductor image sensors. SK Hynix is reportedly stockpiling certain chip-making chemicals on the list of export regulations and seeking to “[diversify] vendors and [minimize] input processes.”
Smartphone manufacturer LG Display stated that it would see “some impact” from any trade condition changes with Japan, but that it does not use fluorinated polyimide for mass production of its displays. On July 23, the company announced that it was planning to diversify its supplier base in an effort to mitigate the impact the restrictions are having on some display-making materials. Compared to their South Korean counterparts, LG Display has alternative sources outside of Japan – most notably through its Guangzhou, China plant used for the production of OLED panels – that can provide the quality of hydrogen fluoride it needs. The company, which is a supplier of Apple, is currently battling a global supply glut of liquid-crystal displays (LCDs) used in television sets.
From a supply chain perspective, the export control curbs are problematic on a number of fronts. For starters, stockpiling is not regarded as a realistic long-term solution: hydrogen fluoride is highly toxic and can be difficult to store in high volumes, while photoresists can deteriorate quickly over time. In an effort to mitigate manufacturing disruptions, Samsung Electronics and SK Hynix have sought alternative suppliers from within South Korea, Taiwan, and China and have dispatched purchasing teams to factories or joint ventures operated by suppliers outside of Japan to secure supplies. Both companies have also called upon South Korean supplier Foosung Company to boost local supplies of hydrogen fluoride with SK Hynix and Samsung offering to run quality tests for its products. Reports estimate that it could take Samsung at least two to three months to determine whether the current quality levels can be maintained for etching gas. Most recently, Samsung is reportedly sourcing extreme ultraviolet photoresists, which are used to deposit circuit patterns onto silicon wafers in the chip making process, from an unspecified Belgium-based company and have bought six to ten months’ worth of inventories. According to the company, Samsung’s smartphone operations still have about three to four months of stock, although the sector is likely to feel the impact of the export curb if the trade dispute lingers.
In the event of further export controls, the Korea Economic Research Institute (KERI) forecasts that Korean chipmakers will suffer a 30 percent setback and that the country’s gross domestic product (GDP) could decline by as much as 2.2 percent.
Removal of South Korea from Japan’s ‘Whitelist’
South Korea became the first country to be removed from Japan’s preferential whitelist of 27 member countries on August 2, which will officially come into an effect on August 28. Countries that are part of the whitelist – such as the U.S., Britain, Germany, Australia, New Zealand, and Argentina – are given customs clearance priority and are subject to less stringent checks for imports. The removal also means that Japanese firms that are supplying about 850 sensitive materials from a range of 40 product categories will have to apply for additional export verifications on a case-by-case basis before exporting to South Korea. These include building materials, chemicals, and technology products such as isotactic presses, frequency changers, pressure transducers, titanium alloys, carbon fiber, vacuum pumps, generators, gyroscopes, crane trucks, and milling machines. According to reports, South Korea’s technology sector is highly dependent on the top 20 items in the list such as scrap steel, medical equipment, plastics, and chemical products.
Under the preferential whitelist, Japan’s METI has already specifically created a list of 40 product categories (see Appendix A) which separates it from other member countries. The items are listed under (i) list regulations and (ii) catch-all regulations. Items that fall under the former are categorized as “high possibility of military diversion” and will require that permission be obtained from the ministry for export regardless of its destination. Items under the second section are categorized as “developing, manufacturing or storing weapons of mass destruction” and will not require approval if the items’ destinations are countries on the whitelist.
According to the Korea Strategic Trade Institute (KSTI), the list of prohibited items could mount up to 1,100 specific items rather than 850. At the time of writing, it remains unclear which items will be affected in terms of increased customs inspections as it is subject to METI’s decision. Thus, it is difficult to anticipate the scale of the problem as regulations can be applied to more items depending on how the situation develops before August 28. The lack of details given by Japan has stirred uncertainties within South Korea as the Korea Trade-Investment Promotion Agency (KOTRA) and Korea International Trade Association (KITA) has no foundation to provide guidelines for its domestic manufacturers that rely on Japan’s imports.
Data acquired by Everstream Analytics indicates that the specific industries which are likely to be impacted by South Korea’s removal from Japan’s whitelist are engineering and manufacturing, machinery, energy, and chemicals. Notable items that will impact Japanese exporters and South Korean importers include crane trucks (which made up 49.3 percent of South Korea’s annual imports in 2018), machine tools (49 percent), and vacuum pumps (48.6 percent).
Samsung Biologics has already warned that it could be vulnerable if Japan were to decide to remove South Korea from the whitelist because it would severely disrupt the supply of materials that are needed for its biopharmaceutical production. In particular, the company could suffer from an immediate supply shortage of virus filters as they are currently only produced in Japan and European countries.
Retaliatory Measures by South Korea
Seoul’s plan to remove Tokyo from its own preferential trade status on August 12 has been interpreted as the latest ‘tit-for-tat’ response in the bilateral trade dispute. South Korean Industry Minister Sung Yun-mo announced that Japan would be listed on a newly-created trade category of countries that have not run their export control regimes in line with “international export control principles,” which will apply to South Korean exports to Japan and could result in lengthier permit application processes.
Japan has not responded to Seoul’s action as an immediate impact is not expected at this time, since Japan does not rely heavily on South Korean products. Amidst all of this, Seoul is still in discussion with its Japanese counterparts to remove South Korea from its whitelist. Nevertheless, Japan has confirmed its intentions to proceed with its measures on August 28.
Since Japan’s initial export curbs began in early July, Seoul has repeatedly pledged to retaliate, with the trade dispute having already been escalated to the World Trade Organization (WTO). President Moon Jae-in has been on record stating that South Korea would use the trade dispute as an opportunity to reduce the country’s dependence on Japanese chemical suppliers and invest KRW 1 trillion (USD 854.41 million; EUR 757.77 million) to produce home-grown materials and equipment such as microchips. Earlier this month, South Korea announced that it would be reducing reliance on 20 specific Japanese exports and that it was considering export controls on DRAM components to Japan as more concrete retaliatory measures.
South Korea hit back on July 11 with retaliatory measures after extending an anti-dumping duty of 30.18 percent on ethyl acetate imports from Japan for three years. The import value of ethyl acetate imports – which are primarily used as a solvent for paints, synthetic resins and inks, and adhesives for liquid crystal display (LCD) panels – is estimated to be at KRW 100 billion (USD 84.68 million; EUR 75.6 million). Japanese suppliers that will continue to be affected include chemical engineering company Showa Denko. However, the impact of extended anti-dumping duties may mostly be minimal given that 91.5 percent of Japan’s ethyl acetate imports come from China alone. In addition, Seoul is also considering extending its anti-dumping duties for the fourth time on imports on stainless steel bars from Japan that is used to produce auto parts and precision industry materials.
The export control curbs have triggered widespread consumer boycott activity against Japanese goods in South Korea, with a list of 100 Japanese companies including Uniqlo, Muji, Descente (retail), Asahi and Kirin (beverages), and DHC (cosmetics) being affected. South Korean airline carrier Korean Air recently announced that it would be suspending flights between Busan and Sapporo, while Asiana Airlines will switch to smaller planes beginning September amid the diplomatic dispute and declining demand. The consumer boycott has also already impacted Japanese automakers, such as Toyota, Honda, and Nissan, with reports of boycotts and vandalism that left luxury vehicles covered in kimchi as a sign of protest. Japanese auto manufacturers make up 19 percent of the foreign car market in South Korea.
Supply Chain Implications
The lingering bilateral trade dispute has sparked fears that the global manufacturing supply chain for semiconductors could be hit by supply shortages and higher prices should the issue be prolonged. Having already been impacted by the ongoing U.S.-China trade war and overall slower growth in the global economy, international sales for major semiconductor companies are projected to decline this year after reaching up to USD 474.6 billion (EUR 425 billion) in 2018. For instance, Japan’s export control restrictions have caused prices to soar as the supply for DRAM memory chips is anticipated to drop. Prior to the export controls, prices were declining earlier this year due to an anticipated excess supply of the chips which resulted in profit losses for Samsung. Industry sources suggest that a reduction in production by 20 to 30 percent could allow Samsung to potentially conserve supplies and halt declining memory chip prices.
Although most global tech companies may be able to make up for the shortfall, maintaining quality levels and the probability of insufficient supplies to fulfill production orders will likely be some of the most immediate concerns for chip manufacturers. Prices for end products such as servers, mobile handsets, personal computers, and other consumer electronics will have an immediate effect on consumers.
The ongoing developments also pose a serious threat to U.S. technology companies, which rely heavily on South Korean semiconductor manufacturers and components for smartphones, computer servers, and laptops. The Semiconductor Industry Association – which represents major U.S. technology giants such as Qualcomm, Intel Corporation, Amazon, Apple, and Sony – issued a joint statement voicing their concerns about the adverse ripple effect that Japan’s restrictions could have on the global tech industry. Apple is a major customer of Samsung and SK Hynix while Dell, Kingston Technology, and Hewlett Packard Enterprise are also among the firms that are likely to be hit if the supply shortage continues. Samsung Electronics has already warned that these developments could impact its Austin, Texas plant and other global technology companies operating out of the U.S.
China’s semiconductor industry has similarly felt the impact of the export curbs, as a sizeable portion of products from Samsung and SK Hynix are manufactured in the country from imported chemical sources from Japan. Around 70 percent of Samsung’s NAND flash memory chips are produced in Shaanxi, while about 30 percent goes to Zhejiang where SK Hynix produces its DRAM chips. Major Chinese smartphone companies are likely to feel the brunt of the impact along with computer and server makers. A major challenge confronting the Chinese semiconductor market is that they are unlikely to be able to fill the immediate supply shortage as China remains several years away from developing more advanced homegrown chips.
Due to uncertainties surrounding bilateral trade tensions, Everstream Analytics customers with suppliers based in Japan and chip manufacturers in South Korea are advised to adopt one or more of the following measures to reduce exposure to the aforementioned risks.
- Plan realistic production schedules: Companies should coordinate with sub-tier suppliers and manufacturers on realistic production schedules amid export restrictions due to the potential cost for late or undelivered intermediate goods.
- Assess supplier preparedness: Customers should liaise with Japanese importers to understand whether export permit applications have been filed in order to evaluate if there will be any gaps due to a three month inspection period. For companies that are sourcing from suppliers affected by the export control regulations, it is imperative that they explore and assess how they may be impacted from a geographical, product flow, and financial perspective. If a supplier is confronted with financial stress or is facing insolvency, this may be reflected in weaker product quality and slower response times.
- Enforce quality control measures: Sourcing from alternative suppliers to make up for the shortfall may temporarily provide companies with some relief when it comes to securing supplies. However, ensuring that product quality is maintained is equally significant in order to uphold performance levels and protect a company’s brand identity. For instance, SK Hynix and Samsung Electronics have already deployed teams at alternative suppliers in South Korea, China, and Taiwan to assess whether quality levels can be properly maintained with the new materials.
- Identify alternative sources: Suppliers and manufacturers are advised to identify alternative sources in different geographic locations to minimize the impact of future trade restrictions. Customers are advised to analyze the extent of the extra costs involved and if sufficient alternative supplies exist in the event of prolonged trade tensions.
- Monitor regulatory updates: Those with business interest in the region and industry are encouraged to continuously monitor further trade regulations that may be introduced through Japan’s METI and South Korea’s KOTRA and KITA websites. Given the high volatility of current trade tensions between South Korea and Japan, it is imperative that Japanese suppliers and South Korean importers are aware of any additional disruptions or customs delays that may emerge on top of the existing trade restrictions.
Tokyo’s latest manoeuvers have been interpreted as a strategic effort aimed at targeting Seoul’s semiconductor industry, but it may have the unintended effect of damaging Japanese exporters more than their South Korean counterparts. The strengthening of export controls has placed considerable pressure on Japanese chemicals suppliers and South Korean semiconductor manufacturers that could accelerate a growing trend of ‘decoupling’ or disintegrating of global tech supply chains. Uncertainty brought about by tariffs through the U.S.-China trade war has already had an impact on trade dependent economies as well as semiconductor and electronics supply chains.
The current, tense diplomatic and trade relations between Japan and South Korea suggest that the two countries are unlikely to come to a mutual agreement in the immediate term. Removing South Korea from the whitelist would certainly strain diplomatic relations between the two as South Korea is reportedly planning to end a military information sharing agreement with Japan amid North Korea’s latest missile tests. The decision to remove Japan will be made on August 24.
As the situation continues to evolve, the conflict could be prolonged following Japan’s decision to remove South Korea from its preferential trade whitelist. Customers with an interest in understanding how the bilateral trade dispute between South Korea and Japan could impact global tech supply chains are advised to continue monitoring developments on Everstream Analytics.
|No.||COMMODITY WATCH LIST||POSSIBLE APPLICATION USE|
|1||Tributyl Phosphate||Nuclear Weapons|
|2||Carbon / Glass / Aramid fiber||Nuclear Weapons, Missile|
|3||Titanium Alloys||Nuclear Weapons, Missile|
|4||Maraging Steel||Nuclear Weapons, Missile|
|5||Aluminum alloy tubes with a diameter of more than 75 mm||Nuclear Weapons|
|6||Flow forming machines||Nuclear Weapons, Missile|
|7||N/ C, Machine tools||Nuclear Weapons, Missile|
|8||Isotactic presses||Nuclear Weapons, Missile|
|9||Filament winding machines||Nuclear Weapons, Missile|
|10||Frequency changers||Nuclear Weapons|
|11||Mass spectrometers ion sources||Nuclear Weapons|
|12||Vibration test systems||Nuclear Weapons, Missile|
|13||Centrifugal multiplane balancing machines||Nuclear Weapons, Missile|
|14||Pressure transducers||Nuclear Weapons, Missile|
|15||Non-destructive inspection equipment||Nuclear Weapons, Missile|
|16||Oscilloscope or waveform digitizers and transient recorders||Nuclear Weapons|
|17||High power/ voltage DC power supplies||Nuclear Weapons|
|19||Vacuum pumps||Nuclear Weapons|
|20||Radiation-hardened robots||Nuclear Weapons|
|21||TIG welding units, electron beam welding units||Nuclear Weapons, Missile|
|22||Radiation monitoring and detection equipment||Nuclear Weapons|
|23||Mill for fine powder||Missile|
|24||Karl Fischer moisture equipment||Missile|
|25||Equipment designed for producing prepregs||Missile|
|26||Artificial graphite||Nuclear Weapons, Missile|
|29||Trucks (Tractors, Trailers, Dump trucks)||Missile|
|31||Chambers for fermentation||Biological Weapons|
|32||Centrifugal separators||Biological Weapons|
|33||Freeze dryers||Biological Weapons|
|34||Reactors||Chemical weapons, Missile|
|35||Agitators||Chemical weapons, Missile|
|36||Heat exchangers or condensers||Chemical weapons, Missile|
|37||Distillation or absorption columns||Chemical weapons, Missile|
|38||Filling equipment||Chemical weapons, Missile|
|39||Unmanned air vehicles that are specially designed for incorporating spray machines||Chemical weapons, Missile, Biological Weapons|
|40||Spray machines that are especially designed for installing in unmanned air vehicles||Biological Weapons, Chemical weapons, Missile|