Dear Yuri Petrovich!

After analyzing the bill consider it necessary to make the following comments and proposals on behalf of GDS “League of defense companies of Ukraine” against the Law of Ukraine” On the creation and production of weapons, military and special equipment”

– In paragraph 4 of Article 2, which deals with the temporary transfer of military products manufacturer for repair, upgrade, etc., it should be noted that the terms of such transfer not only determined by the Cabinet of Ministers of Ukraine, but the contract between the customer and the manufacturer

– Article 3 would be appropriate to complement the point that would determine that the Executive government contract with defense procurement to develop products armaments, military and special equipment remuneration (royalty) in the form of royalties for each copy sold or for each use of intellectual property rights

– Part 1 of Article 4 should be noted that in terms of legal technique impractical in one law to refer to a specific article of a law. After all, if amendments to this article or change its number, it will be necessary to make changes to the proposed law

– Subparagraph 2 of paragraph 1 of Article 5 provides powers to implement export and import of military goods and goods containing information constituting a state secret, conducted under the Law of Ukraine “On state control over international transfers of military and dual-use “. However subparagraph 5 paragraph 1 of the same article provides state export control of international transfers of military and dual-use according to the Law of Ukraine “On state control over international transfers of military and dual-use”, which already regulates the granting of authority to the right export and import of military goods and goods containing information constituting a state secret. Therefore, we believe that we should exclude from Article 5 § 1 of the bill duplicates subparagraph 2

– Paragraph 3 of Article 11 of the bill should specify that the execution of development work related to the creation of new models of weapons, military and special equipment or upgrade can be performed also at the expense of the customer

– Paragraph 1 of Article 16, it would be read as follows “Development of products armament, military and special equipment is producing entities (performer defense order), by performing research and design work to develop samples of such products under the terms of the concluded public contracts perform research and development work, which shall include appropriate performance characteristics (technical) problems “

This interpretation will clearly understand that the development of products with weapons, military and special vehicles can perform entities – legal entities regardless of ownership

– Paragraph 2 of Article 19 should be noted that the modernization of weapons, military and special equipment under the terms of the contract state defense order has an production as the contract party

– Part 2 of Article 28 should determine the purpose of sending copies of the technical project to implement research and development, scientific research and technological work on the development of such products to the General Staff of Ukraine

Sincerely, Executive Director of the League
V.V.Badrak