When an EUC is required, who actually demands one, what it looks like in the US, EU, UK and India, and how (and how well) anyone verifies that the paper matches reality.
In This Article
- What an End User Certificate Actually Certifies
- When You’ll Be Asked for One
- Who Actually Demands an EUC
- Formats: How an EUC Actually Looks
- Authenticity: How an EUC Is Verified — and How It’s Faked
- Case Study: Syria’s Shifting Sanctions Regime
- A Note for Freight Forwarders and Carriers
- Acronyms Used in This Article
- Further Reading
What an End User Certificate Actually Certifies
An end user certificate (EUC) is issued by the importer, buyer, or consignee, certifying the intended use of goods being imported and confirming they won’t be transferred, resold, or re-exported to any other party or country without authorisation. It’s the exporting government’s primary paper-based control against diversion — to unauthorised end users, to embargoed destinations, to weapons programmes, or into the hands of non-state actors.
The UN’s own definition is still the cleanest one I know of — it comes from what’s now called MOSAIC (the Modular Small-arms-control Implementation Compendium), the UN’s guidance series on small arms control, known as the International Small Arms Control Standards (ISACS) until the UN rebranded it in 2018:
“An end-user certificate is an official document, issued by a competent national authority of the importing state, which identifies a government agency of the importing state as the ultimate recipient of an international transfer of weapons.”
That’s written for state-to-state small arms transfers specifically, so take “government agency” loosely — in the broader trade context this article covers, the named end user is far more often a private company: a defence contractor, an airline, a chemicals manufacturer. What carries over is the underlying logic — a competent authority vouching for a named, final recipient — which is what I look for across every controlled-goods category below.
When You’ll Be Asked for One
1. Arms, ammunition and Significant Military Equipment
Class 1 explosives, cartridges, small arms, and what the US ITAR calls “Significant Military Equipment” (SME) consistently trigger EUC requirements. The concern is straightforward: who ends up using the item, against whom, and under what authority. Grenades, incendiary munitions, and fire-control equipment sit in the same bracket.
2. Dual-use goods and technology
Dual-use items — goods with legitimate civilian application but also military or WMD-relevant potential — are, in my experience, the category generating the most EUC paperwork today. Encryption software, high-performance computing, certain machine tools, chemicals, and increasingly cyber-surveillance and AI-adjacent technology fall here. Both the US Export Administration Regulations (EAR) and the EU’s Dual-Use Regulation (EU) 2021/821 require exporters to identify, document, and in defined circumstances certify the end user before export.
3. Chemical weapons precursors
The Chemical Weapons Convention (CWC) controls chemicals and precursors through three schedules, and — this trips people up constantly — only one of the three actually runs on an end-use certificate. The other two work through an outright destination restriction instead. Here’s how the CWC Verification Annex and its national implementations (I’ve used the US EAR as the reference point) actually treat each schedule:
| Schedule | Transfer to CWC States Parties | Transfer to non-States Parties | Formal EUC required? | Example |
|---|---|---|---|---|
| Schedule 1 (few or no use outside chemical weapons) | Permitted, but only for research, medical, pharmaceutical or protective purposes, under advance-notification and annual-reporting rules | Export prohibited outright | No — there’s no certificate that unlocks a Schedule 1 export to a non-Party; it’s simply barred | Ricin, Novichok-family agents (added 2019) |
| Schedule 2 (legitimate small-scale industrial use) | Permitted, subject to national declaration/reporting once you cross a threshold quantity — no licence, no EUC needed for CW reasons specifically (the same ECCN that covers these chemicals, 1C350, also carries a separate CB — chemical/biological weapons — reason for control under §742.2, with its own destination list that applies regardless of CWC State Party status) | Prohibited outright since the Convention’s transitional period expired around 2000 — Schedule 2 chemicals may now only be transferred to or received from States Parties | No — there’s no EUC route to non-Parties at all. Some national laws (the US EAR included) still phrase this as “a licence is required,” but that’s the administrative mechanism for enforcing the treaty’s outright ban, not a real path to export | Thiodiglycol (CAS 111-48-8), dimethyl methylphosphonate |
| Schedule 3 (large-scale commercial use, also weapon-relevant) | Permitted, no licence or EUC needed for CW reasons | Permitted, but only with an End-Use Certificate issued by the government of the importing country | Yes — this is the schedule the EUC mechanism actually belongs to | Thionyl chloride, hydrogen cyanide, phosgene |
In November 2019, the OPCW’s Conference of the States Parties amended the CWC’s Annex on Chemicals for the first time since the treaty entered into force in 1997, adding a family of Novichok nerve agents to Schedule 1; the change took effect on 7 June 2020.
Worked example: does exporting thiodiglycol need an EUC?
Thiodiglycol is Schedule 2B — a recognised, legitimate solvent in inks and felt-tip pen fluids, and also a sulfur mustard precursor. Run it through the table above and the answer is: usually not, and where it is, the requirement isn’t coming from the CWC at all.
- Exporting from the US to a CWC State Party (193 of the world’s ~197 states) — no licence, no EUC needed for CW reasons under 15 CFR 742.18/745.2. The formal “End-Use Certificate” instrument under §745.2 is written for Schedule 3 chemicals specifically; Schedule 2 doesn’t get that route because transfers to non-Parties are barred outright, not merely licence-gated. Worth knowing: this CW-specific carve-out doesn’t touch ECCN 1C350’s separate CB (chemical/biological weapons) reason for control, which runs its own destination list under §742.2 regardless of CWC status.
- Exporting from the US to a state not party to the CWC — the EAR frames this as “a licence is required,” but there’s no EUC that unlocks it, and no real path through it either: Schedule 2 transfers to non-Parties have been prohibited under the Convention itself since its transitional period ended.
- Exporting from India — this is where an EUC comes back into the picture, but as a matter of Indian policy, not CWC treaty law. Thiodiglycol sits under SCOMET Category 1, and DGFT requires an End Use-cum-End User Certificate (Appendix 10J(ii)) if you file a one-off licence on Form ANF 2N. Repeat exporters can instead register once for the five-year General Authorisation for Export of Chemicals (GAEC) — the underlying end-user undertaking is still captured at that initial registration, but GAEC’s whole point is that you’re not re-filing a fresh Appendix 10J for every subsequent shipment, just reporting quarterly. Either way, the requirement applies regardless of whether the buyer is in a CWC State Party or not.
So the same chemical, same end use, gives you two different answers depending only on which country’s export desk you’re sitting at — which is exactly why I check the national implementing regulation rather than assume the treaty schedule alone tells you whether an EUC is coming.
4. Narcotic drug precursors
Chemicals falling under the 1988 UN Convention Against Illicit Traffic in Narcotic Drugs and Psychotropic Substances are split into two tables, and — same pattern as the CWC above — what the treaty actually mandates is narrower than what you’ll be asked for at most national export desks:
| UN Table | What the 1988 Convention itself requires (Article 12) | What that means in practice | Example |
|---|---|---|---|
| Table I (most consequential for illicit manufacture) | Mandatory pre-export notification under Art. 12(10)(a): the exporting country’s competent authority must notify the importing country’s authority before shipment, giving exporter/importer identity, substance, quantity, port of entry and dispatch date. Art. 12(9) additionally permits — but doesn’t require — Parties to run their own import/export authorisation (permit) system on top of this. | Handled today through the INCB’s PEN Online system. Many countries layer a national permit on top of the treaty’s notification floor. | Ephedrine, pseudoephedrine, acetic anhydride, potassium permanganate |
| Table II (broader industrial use, still divertible) | No mandatory pre-export notification under the treaty itself for Table II — Art. 12(9)’s permissive authorisation option still applies | National implementation varies far more widely than for Table I | Acetone, toluene, sulphuric acid, hydrochloric acid |
Supplementing both tables since 2022 is PEN Online Light, for non-scheduled “designer precursor” chemicals that are only nationally — not internationally — controlled.
Worked example: potassium permanganate
Potassium permanganate (CAS 7722-64-7) is the primary oxidiser used to purify cocaine base, and it’s UN Table I — but that single international designation produces three quite different domestic pictures:
- United States — domestically classified as a DEA List II chemical (not List I) under 21 CFR 1310, despite its UN Table I status internationally. The import/export mechanics themselves — including the 15-day advance notice and DEA Form 486 — are set out separately in 21 CFR Part 1313 (specifically §1313.21 for exports): an advance notification the DEA can act on to suspend a shipment, rather than a licence you apply for and wait to be granted.
- India — DGFT’s export policy makes export of potassium permanganate “freely allowed subject to No Objection Certificate (NOC) from the Narcotics Commissioner, Gwalior” (Central Bureau of Narcotics), one of eight precursor chemicals singled out for this treatment. That NOC is, functionally, the permit the treaty’s Article 12(9) merely makes optional — India chose to require it.
- EU/UK — categorised as Category 2B under the EU precursor chemicals regulations, a different tier from the UN Table I label, with its own consignment-authorisation rules distinct from Category 1 substances.
The pattern holds across both chemicals I’ve now walked through in this article: the international instrument (CWC schedule, UN table) tells you the substance is on somebody’s radar; it’s the national implementing law — SCOMET, the NDPS Act and the Narcotics Commissioner, the EAR, the EU precursor regulation — that actually tells you whether you’re filling in a certificate before you can ship.
5. Nuclear and nuclear dual-use items
Items on the Nuclear Suppliers Group (NSG) trigger lists need end-use and non-diversion assurances from the recipient state before export licensing, usually administered alongside International Import Certificate requirements (more on that below).
6. Goods to embargoed or sanctioned destinations
Where a UN, EU, US, or UK sanctions regime is in force, I’ve found an EUC alone is rarely sufficient — a specific licence or derogation from the sanctioning authority is also needed, and it’s typically granted only for food, medical, or humanitarian-purpose goods. The Syria case further down shows how this shifts as a sanctions regime evolves.
Who Actually Demands an EUC
Three distinct parties tend to want to see one, each for a different reason:
| Who | Why |
|---|---|
| Exporting country’s licensing authority | Required as a supporting document before an export licence is issued for controlled goods. |
| Importing country’s government | In many regimes, the importing government — not just the buyer — must counter-sign or issue the certificate, since it is vouching for its own territory. |
| Carrier / freight forwarder / bank | Not a legal requirement in most cases, but carriers, NVOCCs, and trade-finance banks increasingly ask to see an EUC as part of their own denied-party and sanctions screening before accepting a booking or issuing a letter of credit. |
The exporting-country authority itself varies by jurisdiction:
| Country / bloc | Authority |
|---|---|
| United States | Bureau of Industry and Security (BIS) for dual-use/EAR items; Directorate of Defense Trade Controls (DDTC) for ITAR-controlled defence articles |
| United Kingdom | Export Control Joint Unit (ECJU) |
| France | Service des Biens à Double Usage |
| Germany | Federal Office for Economic Affairs and Export Control (BAFA) |
| India | Directorate General of Foreign Trade (DGFT) for most SCOMET categories, with the Department of Atomic Energy handling nuclear-trigger-list items and the Department of Defence Production handling defence stores |
Formats: How an EUC Actually Looks
There’s no single global template — each control regime has its own form, though the substance required (identity of exporter/importer/end user, description and quantity of goods, end use, non-diversion undertaking, signature and stamp of a responsible official) is broadly consistent wherever I’ve encountered it.
United States
- Form BIS-711 (Statement by Ultimate Consignee and Purchaser) — required under EAR §748.11 for license applications involving “600 Series Major Defense Equipment” destined to any country other than the PRC, unless an exception applies (it can also serve as a substitute for the PRC End-User Statement in certain China transactions). Beyond that baseline, BIS can also require it case-by-case for license applications that wouldn’t otherwise need one — in practice this shows up most often for sensitive dual-use sectors like advanced computing, semiconductors, or high-end machine tools. It can be replaced by an equivalent statement on the consignee’s letterhead. Either way, it captures the consignee’s and purchaser’s identity, the item description, and their commitments against misuse, re-export, or diversion. I’d flag one thing for anyone relying on this form: the exporter has to retain it for five years and stays responsible for the accuracy of the information even though it’s the foreign party who signs it.
- Form DSP-83 (Nontransfer and Use Certificate) — required under ITAR §123.10 for the export of Significant Military Equipment and classified defense articles. It has to be executed by the foreign consignee, the foreign end-user, and the applicant, and DDTC can additionally require the government of the destination country to co-sign it where the export goes to a non-governmental end user.
- Form BIS-645P (International Import Certificate) and Form BIS-647P (Delivery Verification Certificate) — the US versions of the international import certificate / delivery verification certificate (IC/DVC) system that many countries use as an alternative to a standalone EUC for civil dual-use goods.
European Union / Wassenaar Arrangement
EU member states each issue EUCs through their own national licensing authority, in a broadly harmonised format required under the recast Dual-Use Regulation (EU) 2021/821, which also introduced a catch-all authorisation requirement for cyber-surveillance items where the exporter’s own due-diligence indicates a risk of internal repression or human-rights misuse. The Wassenaar Arrangement, which India joined as its 42nd participating state in December 2017, doesn’t prescribe one binding EUC template, but its Best Practice Guidelines for arms transfers and its “Elements for Objective Analysis” set out the minimum indicative content — description of goods, quantity, end user, end use, non-re-export undertaking — that member states’ national forms are expected to capture.
The UK’s ECJU draws a distinction worth knowing if you deal with them post-Brexit: most SIEL applications for dual-use goods need an End-User Undertaking (EUU) — a private commitment signed by the end user or stockist, with no government stamp involved. A true End-User Certificate (EUC) is reserved for a narrower case: exporting CWC Schedule 3 chemicals, where it has to be stamped by a recognised government department or ministry in the recipient country, not just signed by the buyer. Notice to Exporters 2025/20 (29 July 2025) consolidated the separate EUU and Stockist Undertaking forms into a single End-user and Stockist Undertaking (EUSU) form, and used the opportunity to modernise it — digital signatures are now accepted, the requirement to submit on company letterhead has been dropped, and the questions were rewritten to match the licence application fields in LITE, the ECJU’s current licensing system. If you last downloaded the old EUU template, it’s worth re-checking gov.uk for the current one.
India — SCOMET
For exports of items on India’s SCOMET list (Special Chemicals, Organisms, Materials, Equipment and Technologies — notified under Appendix 3 to the ITC(HS) Classification, and aligned to the Wassenaar Arrangement, Missile Technology Control Regime, Australia Group, and Nuclear Suppliers Group control lists), the EUC proforma most of us actually fill in is:
- Appendix 10J(i) — the End Use cum End User Certificate for SCOMET Categories 2, 3, 4, 5 and 8, and for re-export from a stockist to the ultimate end user. Every entity in the supply chain — foreign buyer, consignee, end user, and any intermediary — completes it on its own letterhead, signed in ink and stamped by an authorised signatory.
- Appendix 10J(ii) — the equivalent for SCOMET Category 1 (chemicals).
- Appendix 10J(iii) — the proforma for Stock & Sale arrangements.
Applications go through DGFT’s Inter-Ministerial Working Group (IMWG). A one-off, transaction-specific licence is filed on Form ANF 2N. Exporters who ship the same Category 1 chemical repeatedly can instead register once for a General Authorisation for Export of Chemicals (GAEC) — a five-year blanket authorisation under Handbook of Procedures Para 10.16, currently limited to a list of approved destination countries that DGFT has been widening (most recently in July 2025) — subject to quarterly post-shipment reporting. Either route still requires the EUC: GAEC doesn’t remove the certificate, it just replaces shipment-by-shipment filing with one registration plus periodic reporting. Given how often DGFT revises these forms and destination lists, I’d still confirm the live version on the DGFT portal before filing.
On the import side, DGFT issues import licences for restricted, defence-related, or dual-use goods on the strength of an EUC, and Customs verifies the certificate again at the point of clearance — get it wrong and you’re looking at seizure, penalties, prosecution, or denial of future licences under the Foreign Trade (Development & Regulation) Act and the WMD Act, 2005.
Authenticity: How an EUC Is Verified — and How It’s Faked
An EUC is only as good as the willingness and capacity of the issuing authority to stand behind it. I evaluate every case on its own facts: who is the shipper, who is the consignee, who is the actual end user, and what is the declared end use.
Document-level authentication
Where an EUC or a supporting corporate document needs to be recognised across borders, it usually goes through one of two paths:
- Apostille — a single-step certification under the 1961 Hague Apostille Convention, accepted without further embassy involvement in signatory countries.
- Embassy/consular legalisation — a multi-step chain (notarisation → state/national authentication → embassy or consulate of the destination country) required where the destination country hasn’t joined the Hague Convention.
End-use verification programmes
Beyond the paper itself, several governments run active post-shipment verification rather than trusting the certificate alone:
- Blue Lantern (US State Department/DDTC) — end-use checks on Direct Commercial Sales of US Munitions List articles, technology, and brokering.
- Golden Sentry (US) — the equivalent for government-to-government Foreign Military Sales.
- Delivery Verification Certificate (DVC) — confirms goods physically arrived and are held by the declared consignee, used alongside the International Import Certificate for civil dual-use trade.
- PEN Online (INCB) — real-time exchange between exporting and importing governments’ competent authorities before a precursor chemical shipment leaves port, so the importing authority can flag or suspend a suspicious consignment before it arrives.
What I check on any EUC before I’ll rely on it
- Is it issued by a non-government end user, or by the government itself?
- If it’s a non-government end user, is it backed by an import permit from that country’s government?
- Is it backed by (or does the law require) an export permit for the specific goods involved?
- Does it clearly state the end use, and does it include an explicit non-transfer / non-re-export undertaking?
- Do the goods fall under any current international, EU, US, or UK sanctions regime?
- Does it give full, checkable details of both exporter and importer — not just a trading name?
- Is the quantity specific? A certificate silent on quantity or on the exporter’s identity can be reused to procure more goods, from other suppliers, than were ever intended to be authorised.
Mark Bromley and Hugh Griffiths’ “End-User Certificates — Improving Standards to Prevent Diversion” (Stockholm International Peace Research Institute) remains the clearest public breakdown of EUC types and their loopholes.
Case Study: Syria’s Shifting Sanctions Regime
The EU’s Syria sanctions regime (Regulation (EU) No 509/2012 and its amendments) is a clean illustration of how an EUC’s weight shifts as a sanctions programme evolves — export bans on arms and internal-repression equipment, oil and gas technology, precious metals, and monitoring/interception software, layered on top of the underlying arms embargo. That regime has been substantially dismantled since the fall of the Assad government, and it’s worth setting out exactly what changed and what didn’t:
- Following the fall of the Assad government in December 2024, the EU suspended most Syria sanctions from 26 February 2025 and formally lifted nearly all remaining economic sanctions by 29 May 2025, removing 24 entities from its list, including the Central Bank of Syria.
- The US Treasury’s OFAC issued General License 25 on 23 May 2025 suspending most US sanctions; President Trump then signed Executive Order 14312 on 30 June 2025, terminating the US Syria Sanctions Program from 1 July 2025, and OFAC formally removed the Syrian Sanctions Regulations from the Code of Federal Regulations on 26 August 2025.
- The US Commerce Department’s BIS followed with its own Final Rule, “Relaxing Export Controls for Syria,” effective 2 September 2025 — it adds a new EAR99 licence exception and expands several existing ones, but it does not lift the underlying US trade embargo on Syria or remove Syria from the EAR’s list of terrorism-supporting countries, and licensing restrictions tied to the Entity List and to nuclear or chemical/biological-weapon end-uses remain in place.
- The UK eased its sectoral sanctions on energy, transport, banking and finance through 2025.
- The EU’s arms embargo and its export restrictions on equipment and technology usable for internal repression remain explicitly in force throughout.
- On its annual review in May 2026, the EU Council renewed its listing of individuals and entities linked to the former al-Assad regime for a further year, to 1 June 2027, while delisting seven entities — including Syria’s own defence and interior ministries, now under the transitional government. Around the same time, the EU restored full application of the EU-Syria Cooperation Agreement, which had been suspended since 2011.
The practical lesson for exporters and freight forwarders is straightforward: lifting economic sanctions doesn’t automatically lift arms-embargo or EUC-driven controls, and the two need checking separately, against current guidance, before every shipment — not against whatever you last read on the subject.
A Note for Freight Forwarders and Carriers
An EUC isn’t, strictly, a dangerous goods document — you won’t find it on a DG declaration or a bill of lading. But if you’re booking Class 1 explosives, certain Class 6.1/6.2 or radioactive Class 7 cargo, dual-use chemicals, or defence-related equipment, it sits upstream of the shipment: no valid export licence usually means no valid booking, regardless of how correctly the goods are classified, packed, and marked under the IMDG Code. I’m seeing carriers increasingly ask brokers and NVOCCs to confirm, as part of pre-booking screening, that an export licence and any required EUC are in place and that consignee and notify-party names have been checked against denied-party lists — it’s now a standard extension of the sanctions screening most carriers already run.
One related US document worth knowing if you handle American-origin cargo: the Destination Control Statement under 15 CFR §758.6, required on the commercial invoice for any Commerce Control List item that isn’t EAR99. It used to also have to appear on the bill of lading or air waybill, but that requirement was dropped in a November 2016 harmonisation with the ITAR’s equivalent statement — worth knowing if you’re working from an older compliance checklist that still asks for it on the B/L.
Acronyms Used in This Article
| Acronym | Stands for |
|---|---|
| ANF | Aayat Niryat Form (India’s export/import application form series) |
| BAFA | Federal Office for Economic Affairs and Export Control (Germany) |
| BIS | Bureau of Industry and Security (US Department of Commerce) |
| CAS | Chemical Abstracts Service (registry number identifying a specific chemical) |
| CFR | Code of Federal Regulations (US) |
| CWC | Chemical Weapons Convention |
| DCS | Destination Control Statement (US) |
| DDTC | Directorate of Defense Trade Controls (US State Department) |
| DEA | Drug Enforcement Administration (US) |
| DGFT | Directorate General of Foreign Trade (India) |
| DVC | Delivery Verification Certificate |
| EAR | Export Administration Regulations (US) |
| ECJU | Export Control Joint Unit (UK) |
| EUC | End User Certificate |
| EUSU | End-user and Stockist Undertaking (UK, superseded EUU/SU forms in 2025) |
| EUU | End-User Undertaking (UK) |
| GAEC | General Authorisation for Export of Chemicals (India) |
| IC | International Import Certificate |
| IMWG | Inter-Ministerial Working Group (DGFT’s SCOMET licensing body) |
| INCB | International Narcotics Control Board |
| ISACS | International Small Arms Control Standards — the UN series later rebranded MOSAIC |
| ITAR | International Traffic in Arms Regulations (US) |
| MOSAIC | Modular Small-arms-control Implementation Compendium (UN, successor to ISACS) |
| NDPS | Narcotic Drugs and Psychotropic Substances Act (India) |
| NOC | No Objection Certificate |
| NSG | Nuclear Suppliers Group |
| NVOCC | Non-Vessel Operating Common Carrier |
| OFAC | Office of Foreign Assets Control (US Treasury) |
| OPCW | Organisation for the Prohibition of Chemical Weapons |
| PEN | Pre-Export Notification (INCB system for precursor chemicals) |
| SCOMET | Special Chemicals, Organisms, Materials, Equipment and Technologies (India’s control list) |
| SME | Significant Military Equipment (US ITAR term) |
| WMD | Weapons of Mass Destruction |
Further Reading
- Bromley, M. & Griffiths, H., “End-User Certificates — Improving Standards to Prevent Diversion,” SIPRI Insights on Peace and Security, 2010.
- US Bureau of Industry and Security, Export Administration Regulations §748.11 and Supplement No. 3 to Part 748 (Form BIS-711 requirements).
- 22 CFR §123.10 — ITAR Nontransfer and Use Assurances (Form DSP-83).
- Regulation (EU) 2021/821 (recast Dual-Use Regulation) and Delegated Regulation (EU) 2025/2003 amending its control list.
- DGFT Handbook of Procedures, Foreign Trade Policy — Chapter 10 (SCOMET) and Appendix 10J(i)–(iii); confirm current ANF form numbers on the live DGFT portal.
- OPCW, Chemical Weapons Convention — Annex on Chemicals, Schedules 1–3, as amended by decisions C-24/DEC.4 and C-24/DEC.5 of 27 November 2019 (in force 7 June 2020).
- International Narcotics Control Board — PEN Online (restricted to competent national authorities, not directly accessible to exporters) and PEN Online Light, and Precursors Annual Report 2025.
- The Wassenaar Arrangement — Best Practice Guidelines for Exports of Small Arms and Light Weapons; “Elements for Objective Analysis and Advice.”
- UK Export Control Joint Unit, Notice to Exporters 2025/20 — updated End-user and Stockist Undertaking (EUSU) form and guidance, 29 July 2025.
- Council of the European Union, press releases on Syria sanctions, 28 May 2025 and 18 May 2026; U.S. Federal Register, “Relaxing Export Controls for Syria,” 2 September 2025.
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