This Statement is issued by UAB “QS Lasers” (Mokslininkų g. 6B, LT-08412 Vilnius, Lithuania; hereinafter “the Company”) in order to:

• inform customers, suppliers, logistics providers, financial institutions, and other stakeholders of the statutory requirements governing the export, import, transit, brokering, and technical assistance of dual-use goods and laser products handled by the Company;
• demonstrate the Company’s commitment to full compliance with European Union (“EU”) and Republic of Lithuania strategic-trade controls and sanctions; and
• facilitate transparent business conduct by describing the obligations that counterparties must observe when engaging in transactions involving the Company’s products, services, or technical data.

II. Governing Legal Framework (non-exhaustive)

III. Scope of Control

The Company’s products include laser systems, laser modules, and laser components. Lasers and related optical systems may qualify as dual-use items under Category 6 (Sensors and Lasers) of Annex I to Regulation (EU) 2021/821. The Company evaluates each product and transaction to determine whether an export licence or other authorisation is required.

The following categories are subject to control:

Dual-use items

Goods, software, and technology listed in Annex I to Regulation 2021/821 or otherwise subject to a catch-all licensing requirement where the exporter knows or has been informed of:

• a potential connection to weapons of mass destruction (WMD) programmes;
• a military end-use in an embargoed destination; or
• use as components for illicitly exported military items.

Very-sensitive dual-use items

Items listed in Annex IV to Regulation 2021/821 require a licence even for intra-EU transfers.

Military items

Articles enumerated in the Lithuanian National Military List or the EU Common Military List. All movements (export, import, transit, brokering) require prior authorisation from the Ministry of Economy and Innovation.

Intangible Transfers of Technology (ITT)

Electronic transmission of controlled technical data or software to a foreign national or third country constitutes an export under EU law and is subject to the same licensing requirements as physical goods.

IV. Classification, Licensing, and Pre-Shipment Procedure

4.1 Product Classification

Prior to each export transaction, QS Lasers assesses whether the Goods fall under Annex I to Regulation (EU) 2021/821.

Where a product is determined not to be listed, QS Lasers confirms this assessment and retains the documentation for record-keeping purposes.

Where a product is listed, the applicable licence or general export authorisation is obtained before the customs declaration is lodged.

4.2 Counterparty and Destination Screening

Before accepting each order, QS Lasers screens the customer, end-user, consignee, and destination country against:

• the EU Consolidated Financial Sanctions List;
• the EU Sanctions Map (sanctionsmap.eu);
• applicable national embargo notices; and
• the TARIC database for any trade restrictions applicable to the product and destination.

4.3 End-User Documentation

For exports to third countries (non-EU), QS Lasers requires the Customer to provide a signed End-User Statement (EUS) confirming the stated end-use, end-user identity, and destination, and undertaking not to re-export the Goods without the Company’s prior written consent and any required authorisation.

4.4 Licensing Authority

The Ministry of Economy and Innovation of the Republic of Lithuania is the competent authority for issuing individual, global, and general export licences for dual-use and military items.

Authorisation decisions consider Lithuania’s international non-proliferation commitments (Wassenaar Arrangement, Nuclear Suppliers Group, MTCR, Australia Group), binding UN Security Council resolutions, EU restrictive measures, and the credibility of the stated end-use.

V. Record-Keeping Obligations

In accordance with Article 24 of Regulation (EU) 2021/821, QS Lasers retains all commercial, transport, technical, and correspondence records relating to export transactions for a minimum of three (3) years from the end of the calendar year in which the transaction took place.

Records are made available to competent authorities upon request.

VI. Sanctions and Enforcement

Failure to comply with export control and sanctions obligations may result in:

• Criminal liability – imprisonment of up to eight (8) years and/or substantial fines for unauthorised export, brokering, or transit of strategic goods (Arts 199 & 258, Criminal Code of Lithuania).
• Administrative liability – fines, confiscation, licence withdrawal, and exclusion from public procurement (Art 141, Code of Administrative Offences of Lithuania).
• Civil and contractual remedies – the Company may cancel contracts, suspend deliveries, and claim indemnification for compliance-related losses.

VII. Obligations of Customers and Counterparties

All customers, distributors, agents, and other counterparties of QS Lasers are required to comply with the following obligations.

Screening

Prior to placing any order or accepting delivery, verify end-users, consignees, financial institutions, and destinations against the EU Consolidated Sanctions List, the EU Sanctions Map, and applicable national embargo notices.

Accurate information

Provide complete and truthful data on end-use, end-user, routing, and licensing status. Any change in end-use or end-user must be communicated to QS Lasers without delay.

No diversion

Re-export, re-transfer, lease, or re-sell controlled items or related technical data only with QS Lasers’ prior written consent and, where applicable, a new Union or national licence.

Russia/Belarus Sanctions Undertaking

Pursuant to Article 12g of Council Regulation (EU) No 833/2014, any customer purchasing QS Lasers Goods undertakes that:

• the Customer shall neither directly nor indirectly sell, export, re-export, transfer, lease, or otherwise make available any QS Lasers Goods, software, or technology to the Russian Federation or the Republic of Belarus, or for use therein;
• the Customer shall impose equivalent prohibitions on all subsequent buyers, resellers, or other parties down the supply chain, and shall implement adequate due-diligence, screening, and monitoring procedures to detect and prevent circumvention; and
• the Customer shall notify QS Lasers without delay of any actual or suspected diversion, attempted diversion, or difficulty in applying this undertaking.

Prompt notification

Inform QS Lasers immediately of any change in end-use, end-user identity, or any suspicion that a transaction may breach export-control or sanctions law.

VIII. Reservation of Rights and Contractual Penalties

QS Lasers reserves the right to decline, suspend, or cancel any transaction that, in its reasonable judgement, poses an unacceptable compliance risk or conflicts with EU or national law.

Any actual or attempted breach of the Russia/Belarus Sanctions Undertaking (Section VII) or of any other export-control obligation constitutes a material breach of an essential contractual element.

In such event, QS Lasers may, without prejudice to any other remedy:

• terminate the contract with immediate effect; and
• demand liquidated damages equal to the greater of one hundred percent (100%) of the total contract value or fifty thousand euro (€50,000), payable within ten (10) calendar days of written notice.

The Customer expressly acknowledges that this represents a genuine pre-estimate of QS Lasers’ minimum compliance-related loss.

QS Lasers retains the right to seek additional damages if actual losses exceed the liquidated amount.

IX. Reference Instruments

• Regulation (EU) 2021/821 of the European Parliament and of the Council – OJ L 206, 11 Jun 2021.
• Commission Delegated Regulation (EU) 2024/2547 – OJ L, 7 Nov 2024.
• Commission Delegated Regulation (EU) 2023/996 – OJ L 153, 2 Jun 2023.
• Council Common Position 2008/944/CFSP – OJ L 335, 13 Dec 2008.
• Council Regulation (EU) No 833/2014 (consolidated).
• Law on the Control of Strategic Goods No. I-1022 (Lithuania).
• Order No. V-720 of the Minister of National Defence (Lithuania) – 27 Sep 2022.
• Criminal Code of the Republic of Lithuania – Arts 199 & 258.
• Code of Administrative Offences of the Republic of Lithuania – Art 141.
• EU Sanctions Map: https://www.sanctionsmap.eu
• TARIC Database: https://ec.europa.eu/taxation_customs/dds2/taric/

X. Disclaimer

This Statement is provided for general information purposes only, does not constitute legal advice, and does not create any obligation beyond those expressly incorporated into written contracts with the Company.

Stakeholders are encouraged to seek specialist legal counsel or contact the competent national authority for transaction-specific guidance.