Grasping the nettle: Ending Europe’s Trade in Execution and Torture Technology 49 in such devices would come within the object and purpose of EC Regulation 1236/2005 and such goods should therefore be added to Annex III. Review of Member State implementation of the Regulation In addition to ensuring that the Regulation and the attendant control regime are evolving to meet changes in security equipment development and patterns of (mis)use, a regular and comprehensive review mechanism (as proposed by Amnesty International and Omega) should also monitor Member State implementation of the Regulation and specifically analyse Member State licensing activities for goods covered under the scope of the Regulation. Article 6 of the Regulation obliges Member States to regulate the export of controlled items, and to deny authorizations for exports of such items, “When there are reasonable grounds to believe that goods listed in Annex III might be used for torture or other cruel, inhuman or degrading treatment or punishment.” Under Article 6.1: “[d]ecisions on applications for authorization for the export of goods listed in Annex III shall be taken by the competent authority on a case by case basis, taking into account all relevant considerations, including in particular, whether an application for authorization of an essentially identical export has been dismissed by another Member State in the preceding three years.” Full information about all licences granted and denied under the Regulation across the EU is not publicly available. However, certain States do provide public information on licensing activities.240 Some of this data raises serious concerns that certain Member States are not consistently assessing the risk that items covered by the Regulation may be misused for torture or other ill-treatment in specific recipient States, as required by Article 6 of the Regulation. Certain Member States (such as the Czech Republic) have granted export licences for particular categories of goods to a number of countries where the same category of goods appear to have been used for torture and other ill-treatment, according to recent reports by Amnesty International and other human rights organisations. These concerns cannot be confirmed or allayed without further information regarding the intended end-user of the items in each case: information which is also not systematically available. 240 For further discussion see: Amnesty International & Omega Research Foundation, Europe: From words to deeds: Making the EU ban on the trade in ‘tools of torture’ a reality”, EUR 01/004/2010, 17 March 2010. Index: EUR 01/1632/2015 Amnesty International May 2015