sale by a range of companies in the US and elsewhere, previously including the CoE-based company, De Ridder Products, which has offices in Belgium, France, Germany and the Netherlands.233 On 29 April 2015, in response to an information request from Amnesty International and the Omega Research Foundation, De Ridder stated: “After reading your report we have decided to delete the mentioned chair out of our assortment and we have also removed it from our website. After taking everything in consideration we come to the conclusion that this product does not match our vision on safety for the prisoners when used wrongly.”234 In addition, Amnesty International and the Omega Research Foundation have previously uncovered evidence of the promotion of restraint chairs by non-CoE companies at CoE arms and security fairs and exhibitions in 2011.235 The European Commission has recognised that restraint chairs, shackle boards and shackle beds, “Restrict movement of the prisoner much more than simultaneous application of e.g. handcuffs and ankle cuffs. The inherent risk of torture or inhuman treatment increases when this restraining technique is applied for longer periods.” The Commission concluded that “It is therefore necessary to prohibit the trade in restraint chairs, shackle boards and shackle beds.” Consequently, in July 2014, the Commission added restraint chairs, shackle boards and shackle beds to the list of prohibited goods whose import to the EU or export from the EU was prohibited under EC Regulation 1236/2005. In December 2016 promotion of such goods was also prohibited under EU Regulation 2016/2134. Although these prohibitions cover restraint chairs, boards and beds employing metal restraints, they do not cover devices “fitted with straps”.236 These exemptions allow the uncontrolled promotion and transfer of such restraint chairs, boards and beds into or from the EU. These loopholes need to be urgently addressed. It is unknown whether any non-EU CoE member States currently control or prohibit the trade in such devices. 5.2.3.3.Recommendations  CoE member States should prohibit the manufacture, promotion, import, export, brokering or other transfer of restraint chairs, beds, or boards intended for law enforcement purposes.  CoE member States should introduce stringent controls on the trade and use of restraint chairs, beds and boards utilising fabric straps to ensure they are only employed by trained health professionals solely for medical purposes. 233 De Ridder Products, http://www.deridderproducts.com/index.php?route=product/product&product_id=1336 (accessed 13 February 2015). As stated in its response to Amnesty International and the Omega Research Foundation, De Ridder subsequently removed all details of the safety restraint chair from its website. 234 Email correspondence from representative of De Ridder Products, 29 April 2015. 235 Amnesty International & Omega Research Foundation, No more delays: putting an end to the EU trade in “tools of torture”, ACT 30/06/2012. 236 European Commission, Commission Implementing Regulation (EU) No 775/2014 of 16 July 2014. 48

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