APVM Electronics convicted for attempting to export 9098 chips without MFAT notice

An electronics exporter was convicted over unnotified shipments to Singapore and Hong Kong. Photo / Customs NZ
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A New Zealand electronics company has been fined $18,720 after exporting electronic components with potential military applications without notifying authorities.

APVM Electronics faced the Manukau District Court on October 1 and was convicted on two charges under the Customs and Excise Act 2018.

According to Customs, the company attempted to export 9098 integrated circuits (ICs) in two shipments during March 2025 without notifying the Ministry of Foreign Affairs and Trade (MFAT) as required under New Zealand export-control laws.

Customs said this prosecution set an important precedent, showing businesses cannot treat export controls as a box-ticking exercise.

The first shipment involved 9000 ICs destined for an entity in Singapore on March 7, 2025. A second shipment of 98 ICs was destined for an entity in Hong Kong on March 31, 2025.

Customs said the components were seized before either consignment left New Zealand.

ICs are commonly used in consumer electronics, computers and communications equipment. However, some types can also be used in military systems, including drones, weapons-guidance technology and missile systems. Goods with both civilian and potential military uses are known as “dual-use” goods.

An electronics exporter was convicted over unnotified shipments to Singapore and Hong Kong. Photo / Customs NZ
An electronics exporter was convicted over unnotified shipments to Singapore and Hong Kong. Photo / Customs NZ

Under New Zealand law, exporters must notify MFAT if they know, or should reasonably know, that goods may be used in the development, production or deployment of military equipment, or have a potential military application.

The company pleaded guilty to both charges. Each offence carries a maximum fine of $25,000.

Customs investigations manager Dominic Adams said the case highlighted the importance of exporters understanding the nature of the goods they are sending overseas and their possible end use.

“Exporters have a legal responsibility to understand what they are sending overseas, where it is going and how it may ultimately be used,” Adams said.

APVM Electronics was fined after Customs blocked the export of components with potential military applications. Photo / Customs NZ
APVM Electronics was fined after Customs blocked the export of components with potential military applications. Photo / Customs NZ

He said notifying MFAT allowed authorities to assess the goods, destination, recipient and intended use before export.

Customs described the prosecution as the first of its kind. Adams said enforcement of export controls was intended to help prevent the spread of technologies that could be used in military systems and to demonstrate New Zealand’s compliance with international obligations.

The investigation was carried out with assistance from MFAT, which advised Customs on the classification of the components and their potential military uses.

After conviction, the seized goods were automatically forfeited to the Crown unless a court orders their return under the Customs and Excise Act.

The Herald has contacted APVM Electronics for comment.