Advisers have queried whether the information provided with applications for licences will enable the Hong Kong authorities to collect data on the amount of controlled substances used for feedstocks and the amounts destroyed by approved technologies. They also wonder whether the information obtained from licence applications will be sufficient to enable Hong Kong to fulfil the reporting obligations or whether importers or exporters of controlled substances etc should be required to provide specified data annually to Hong Kong Government. (See Article 13 of EC Regulation 594/91 - copy by bag). I should be grateful for your comments. If any further legislation is required we assume that it can be done by making regulations under Section 16, rather than by enacting new primary legislation. Again, I should be grateful for clarification.
5. We are of the view that the apparent deficiencies in the legislation are relatively minor and need not hold up the extension of UK's ratification of the London Amendment to Hong Kong. However, before we submit the necessary documents to the UN Depositary through the UK Mission to the UN in New York we need to be sure that Hong Kong would be able to make any further regulations which may be necessary before the extension takes effect (ie ninety days after the deposit of the notification).
6. I will reply separately to the points raised in your letter of 1 July.
Yours sincerely, ускно
Ausicgroood
Mrs S E Hogwood
Environment, Science and
Energy Department
cc: Ms Barrett, Assistant Legal Adviser
Ms Adams, Legal Adviser, DOE
Ms Godfrey, GA3, doe
Ms Lamont, Envt Divn, DTI
Mr Bunten, HKD
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