The US used the national defense production act to block any export of BioNTech/Pfizer vaccine produced in the US to other countries, so no, this is not just "These vaccine deals are with private companies who produce their product around the world." - countries can and do influence these deals if it benefits them. UK did the same thing.
Don’t conflate the ability to negotiate carefully with banning exports. The private company AZ signed a contract with the British govt according to which they can export once they have delivered the agreed doses to the U.K. the faster they deliver on their commitments, the faster they can start exporting. No one forced them to sign the deal and no one in the UK is banning exports of the vaccine.
If the EU had paid for the vaccine's development, they could have had the deal instead.
But they didn't.
And how much would be the EU's "fair" share of vaccine manufactured in the UK? As they seem to be expecting far more than that 25% for themselves, from their retoric they wanted it "evenly" distributed, i.e. massively in their favour, directly from Ms Von der Leyen's mouth:
“That is the message to AstraZeneca, ‘You fulfil your contract with Europe before you start delivering to other countries’.”
There's nothing "fair" about the EU's distribution of the vaccine, claiming otherwise shows complete naivety or bare faced lying.
And US companies ARE under an export ban.
So your point is?
The Oxford/Merck deal would have been with Merck KGaA, as far as I know. The US government would have had no means to apply export bans to a German-based company.
That sounded implausible. The country which had the ability to negotiate that happened to be the same country where the doses were manufactured? Why couldn't the UK apply its careful negotiating skills elsewhere too?
Alternative hypothesis: the credible implicit or explicit threats of a ban were what enabled the deal. "Sign this or else."
Also remember the vaccine was developed by Oxford using a significant amount of UK government funding, and was licensed to other countries, such as India, for low cost manufacturing.
We did also buy a lot of vaccine from other places (e.g. Pfizer which is also being widely deployed). But with AZ in particular (and to some extent Novavax) there was a focus on building a local supply chain so that countries can't play games with our vaccine supply. Supposedly Pfizer turned down the offer to build UK based factories.
So did the EU.
> Also remember the vaccine was developed by Oxford using a significant amount of UK government funding
And Biontech was developed with German funding. Did Germany insist on exclusivity? Maybe we should have...
- Most of the AZ vaccine for the UK is being made in the UK. AZ have said none of their vaccines have been sent from the EU to the UK.
- AstraZeneca said its agreement with the EU allowed the option of supplying Europe from UK sites, but only once the UK had sufficient supplies (due to the contract the UK negotiated) .
- A drop in confidence in the AZ vaccine means there are lots of unused vaccines. France and Germany have used only about half of the AstraZeneca jabs they have received, according to the European Centre for Disease Prevention and Control (ECDC).
- 10 million Pfizer-BioNTech vaccines have been exported from the EU to the UK.
Sources:
https://www.bbc.co.uk/news/56483766
https://www.politico.eu/article/the-key-differences-between-...
Now why might they have only used half so far, of a vaccine requiring two jabs?
They are keeping the other half for the required 2nd jab.
For some bizarre reason, they are not confident about timely delivery of future supplies.
After the wild "let us suspend AZ and let us restart it in two days" ride, it will be much harder to get AZ into arms of European patients. Even here in the Czech Republic, where AZ wasn't suspended, the reverbations in the public are stark and all kinds of half-baked conspiracies started circulating. (An example: "Germans want to get rid of a junk vaccine and force it on us Slavic untermenschen, while they will only use more expensive and better Pfizer for themselves.")
[0] https://yougov.co.uk/topics/international/articles-reports/2...
(b) This wasn't without reason. AZ has significantly more severe side effects and is less effective.
(c) That said, I'd certainly still take it, it is highly effective at preventing the worst outcomes.
(d) That said, the whole "consumer confidence" narrative is a canard. Its effects don't come anywhere near the effect of the delivery shortfalls. It's so totally ridiculous that it does make me wonder where it is coming from.
How much did they fund before the initial order? I can't seem to find a source. All the results just talk about their down payment not the initial funding like the UKs £65m. https://www.bbc.co.uk/news/56483766
[1] https://news.sky.com/story/covid-19-rejected-contracts-and-a...
There appears to be a similar deal with Novavax to setup similar domestic capacity in the UK for its vaccine.
Yes, having the industrial base is part of the attraction of the UK for pharmaceutical companies. As is having a skilled workforce and a reliable system of laws.
I’m rejecting your original point about the U.S. and U.K. doing the same thing, which they aren’t.
However the EU contract seems to insist the initial 300M doses are made within the EU itself, and the EU has its own dedicated supply chain regardless that can eventually deliver, so this also seems to exclude conflict with the U.K. contract.
This is false. The DPA was invoked in order to a) block the export of certain raw materials in order to prioritise local production of vaccines and b) to compel drugmaker Merck to help produce its competitor Johnson & Johnson’s COVID-19 vaccine.[1] It does not block the export of vaccines. The White House clarified this last week as well.
[1] https://www.hhs.gov/about/news/2021/03/02/biden-administrati...
The U.S. Is Sitting on Tens of Millions of Vaccine Doses the World Needs https://www.nytimes.com/2021/03/11/us/politics/coronavirus-a...
US agrees to share AstraZeneca vaccines with Mexico, Canada https://amp.france24.com/en/americas/20210319-closing-in-on-...
From your own nytimes link:
>"Last May, the Trump administration pledged up to $1.2 billion to AstraZeneca to finance the development and manufacturing of its vaccine, which it developed with the University of Oxford, and to supply the United States with 300 million doses if it proved effective."
AstraZenca is free to export any vaccine beyond their contractual obligation of those doses. Jane Psaki confirmed as much in her WH press conference on Thursday.
Tell that to Canada. They were securing doses from day one and still suffered from delayed shipments and now have to contend with countries of manufacture forbidding export. What really pisses me off is that the US Gov had 30 million doses of Astra for several months and it it isn't even approved for use. Why hoard it when you can save lives in other countries while you have no intention of using it soon if ever? Sure they might get their approval in May or June but by then I expect the other manufacturers to have ramped up to cover everyone everywhere.
There might be perfectly valid reasons for this- I am not sure to what extent the government could or would want to force it to fast-track.
The FDA is already reluctant to use trials from jurisdictions that may be very different demographically. When the trials are marginal, confused, and confounded, the chance of a FDA approval become negligible.
If the AZ US trial pops out good data, you can expect a speedy EUA application.
Canada put all their eggs in the CanSino vaccine even though they knew they had a bad relationship with China. This summer China conveniently blocked all progress and Canada was left scrambling. Blame Trudeau not the US.
Article
https://www.ctvnews.ca/health/coronavirus/canada-locks-in-20...
After securing 20 million doses of the Pfizer vaccine, they exercised an option in early Jan 2021 for another 20 million.
Article
https://www.thestar.com/politics/federal/2020/12/16/why-did-...
Canada has purchased 40 million doses from Moderna, and expects delivery of up to 168,000 doses before the end of December 2020
Article
https://nationalpost.com/news/world/canada-the-biggest-hoard...
Canada the biggest hoarder of COVID-19 vaccine pre-orders in First World, NGOs say
Canada only bought doses from other companies after CanSino fell through in summer 2020 putting them at the back of the line.
https://nationalpost.com/news/moderna-chairman-says-canada-n...
“ Early last year, Canada also signed an agreement with Chinese vaccine-maker CanSino for a vaccine trial, but that deal fell apart. CanSino had initially agreed to bring its vaccine candidate to Canada for testing.Critics have accused the federal government of failing to move swiftly to secure agreements with the likes of Pfizer and Moderna because it was focused on that failed deal.”
https://www.bbc.com/news/world-us-canada-56035306
My sister is a pharmacist in Toronto. She is personally vaccinating people right now as we speak. She said as of last week Ontario only had 200,000 Astra Zeneca vaccine doses allocated to it until April. 200,000 for 15 million people. She says that maybe Ontario may get more on Friday via the US sending more AZ but there’s no information about anything else. Until a few days ago, AZ could not be given to anyone over 64 which caused a lot of confusion and anger. And then Ford said in a conference that they were letting people get the AZ vaccine but they didn’t let the pharmacies know ahead of time, causing even more confusion.
My mom who is in her 80s, her second dose of Pfizer was just recently pushed out by 4 months because they don’t have enough supply. My aunt who is in her 70s couldn’t register (until recently as I mentioned) for a shot because they didn’t have any supply for her age range.
So no, Canada doesn’t have the doses it needs. It’s last in line because they started negotiating months after every other country and only after CanSino deal crumbled.
And yet, Canada is substantially behind the EU on receiving doses, despite putting an order in more than a month earlier.
Given that the US only came to the agreement two weeks before Canada, I don't think Trudeau was sitting on his hands, waiting months for the CanSino deal to fall apart, before exploring alternative options. Seems to be a bit of an exaggeration by the Tories.
Biggest problem of Canada? There’s no local manufacture. And yes you can blame the liberals for that. Your anti Chinese talking point is not based in facts.
But because the first of those four deals fell through (and because the countries manufacturing vaccines bought in other deals are prioritizing their domestic markets), politicians of all party affiliations now have an excuse to grouse.
The drugmaker must apply for emergency use authorization before it can't be approved in the first place. They still have not applied for EUA as of today.
On the other hand the UK still has a fully nationalised health service which means that it was in a much better position to be able to scale the vaccinations. That's probably the real reason that they're ahead.
Give it another 10 years of Tory rule and they'll "catch down" to the rest of the world.
So it is simultaneously true that they signed a contract within a few days of each other, but also not quite the full picture.
https://www.politico.eu/article/the-key-differences-between-...
The conclusion, at least as I interpret it, is that both the UK and the EU can reasonably claim to have priority, based on their respective contracts, but that the UK did a better job than the EU in making theirs enforceable. Hence, AstraZeneca has prioritised them, while the EU has been forced to resort to political rather than legal measures to attempt redress (publishing the contract, export controls, etc.). And the UK's closer ties to the AstraZeneca vaccine project likely did mean they started work on the UK supply chain somewhat earlier than in the EU, even although the final contracts were signed essentially simultaneously (one day apart).
I honestly don't really see this as an affair with clear good guys and bad guys, but it seems like most people are determined to do so, and inevitably along the lines of their pre-existing sympathies.
If you have multiple customers, who signed slightly different contracts at different times, and who also have different side agreements regarding specific facilities they may have paid for in part or in whole, you really need to define how you make allocation decisions in case of shortfall so that everyone understands their risk exposure.
I will personally hold the EC responsible because although AZ has also messed up by not negotiating a clearer contract, it is the EC that indirectly works for me and it is their job to think about this on my and my family's behalf. Had they understood the consequences of being so far back in the production queue much earlier they could have spent more on upgrading production but it is not clear to me that they even understood this until January. While I'm sure that they are trying their best, and bad luck with Sanofi plays a part here as well (as does the incompetence of e.g. the Dutch government in managing distribution), I am pretty unimpressed with how they have dropped the ball here.
It's not good them saying, "oh AZ isn't producing as much as they thought they would". Ok, cool story bro but they're making a novel biological, so you should have anticipated this and done more to prepare plans B, C, all the way through F. Not just placed a few commercial orders and then hope it all works out.
Then there is indeed a difference in contract law, where the UK is far more focused on the letter of the contract, while European law is more about 'what could have been done'.
In the middle of a pandemic there isn't much we can do against pharmaceuticals. In the mean while has Az delivered more than Moderna until now. So, we should take what we can. Only thing we could blame the EC on is that we should not have based our strategy of vaccinating out on such an unreliable, inexperienced partner with a complicated biological process. Looking back and keeping the Pfizer vaccin European would have been less naive, but we would have started these vaccins wars. Will be interesting what the long term consequences are of having UK and US vaccinated two months sooner. I don't think Europe will forget this.
But does the AZ-EU Advance Purchase Agreement[1], which is the somewhat redacted document that was published, talk about 4 different sites? I haven't found anything about specific sites so far, nor any guarantee that there are no competing customers. Have I missed something?
In section 5.1, it does state that AZ shall use its BREs to manufacturer the Initial European Doses within the EU. Then in section 5.4, it states that AZ shall use its BREs to manufacture the Vaccine at manufacturing sites located within the EU, and that specifically for section 5.4 only, that includes the UK. If the exception proves the rule, those sections together appear to imply that AZ must try to manufacture those initial batches for the EU within the EU not including the UK, and then any subsequent manufacture can be done in either the EU or UK (and otherwise there are some additional provisions about other possibilities). Maybe a lawyer can comment on the choice of language there, but it seems awkwardly written to me.
[1] https://www.rai.it/dl/doc/2021/02/19/1613725900577_AZ_FIRMAT...
In the event, it seems neither Boris nor Biden seem very interested in considering anyone else before they've scored enough points at home, and meanwhile real international cooperation on vaccine deliveries is dead. Oh well, hope not all trade follows that pattern shrug.
Similarly - the NHS is great, but not unique. Norway for example has a system akin to the NHS (and so do many EU countries) and there's no correlation there. Norway is waaaaay behind the UK and the US. Again, it seems unlikely that the NHS is the cause.
It's obvious you hate the Tories, but that shouldn't cloud your judgment to such a degree that you fail to celebrate the real achievement of the UK's vaccination rate.
Because nobody applied for approval for the longest time. It was just a few weeks ago that a German company decided to apply for this approval. Now the wheels of assessment are turning.
https://www.ema.europa.eu/en/news/ema-starts-rolling-review-...
According to Dominic Cummings recent select committee hearing, the vaccine programme was largely built outside/adjacent to any existing NHS processes. It was given NHS branding for public trust reasons (just like the new-from-the-ground-up Track and Trace endeavour).
Believe Cummings point was that The Department of Health wasn’t in control as it is in terms of test and trace. So NHS + Cabinet office (and not DHSC’s normal red tape, funding models) = success.
However, I think “sources” in the vaccination task force have said Cummings is full of it.
“That is why we had to take the vaccine process out of the Department of Health.”
Q193, https://committees.parliament.uk/oralevidence/1911/html/
I therefore don't in any way trust his self-assessment of his own department's work and the 'vaccine task force' he set up, which incidentally hired some of his associates, who were paid very well, for example the PR firm:
https://www.ft.com/content/6159d5b7-171c-49ed-b318-144efcc4c...
A director of the public relations firm paid £670,000 to advise the head of the UK government's coronavirus vaccine task force is a longstanding business associate of Dominic Cummings.
EU doesn't have problems with vaccination but with supply of vaccines, we use up all we can get (at least until AZ issues, now people are afraid to vaccinate with it).
There are many (all?) countries in EU that have health service nationalised in EU. The only country I know that doesn't is US.
e.g. germany is holding up a ton of vaccines for the second shot right now, so no, we are not using everything we have. Supply is one thing, distribution is another. And the EU has trouble sorting out the latter, a problem that will hurt even when supply increases to a point were there will be more doses than needed around June/July.
(You are right I forgot about second dozes, but I think that's a good thing considering manufacturers are not supplying us on schedule - and some stupid countries - like mine - use up all vaccines and hope that there will be a second doze in 6 weeks).
https://en.wikipedia.org/wiki/Pfizer%E2%80%93BioNTech_COVID-...
1. Planners are penny-wise, and pound foolish.
2. Everyone's just blindly hoping that we won't have to repeat the quarantine-wait-a-year-and-a-half-for-vaccines for the inevitable tide of COVID-19 variants, that will be evolving in the world's unvaccinated populations.
Look, the people who should have been sorting out vaccines were running around like headless chickens trying to deal with a global pandemic.
Nobody has experience with this, and pretty much all Western governments thought they were done post June 2020, which clearly wasn't the case.
They focused on other things (and there were lots of other things to focus on), and it's caused massive problems now.
I completely agree that we should have built more manufacturing, but we didn't know which vaccines would work at the time.
To be honest, the only people who could have actually made this happen was the US Federal Government in 2020, and they were focused on different things.
And have you offered to supply your government with all your vast supply chain knowledge? This stuff is complicated, and one link in the chain failing reduces all capacity.
I'm also super disappointed at the lack of ambition, to be honest (every human should be vaccinated by EOY if we actually want this to be done), but given my experience running much smaller scale logistics, I'm amazed we've done as well as we have.
As I note above, the US Feds could definitely have done better, as could the EU, but there's a sense of deference to private providers which I find unwarranted, and which could be the cause of the slowness.
There was lots of talk about cronyism when Kate Bingham was appointed to run the vaccine task force but taking bets and investing early even when outcomes weren't know is one thing the UK seems to have done well in the last year
https://www.repubblica.it/cronaca/2021/02/07/news/kate_bingh...
Also, BioNTech has partnered with German Evonik[3] and Merck[4] to accelerate vital lipids production by the second half of 2021.
[1] https://www.wsj.com/articles/biontech-recruits-rivals-to-boo...
[2] https://endpts.com/biontech-teams-up-with-fosun-pharma-to-te...
[3] https://corporate.evonik.com/en/evonik-strengthens-strategic...
[4] https://www.merckgroup.com/en/news/biontech-strategic-partne...
https://www.ctvnews.ca/politics/trump-signs-order-to-put-ame...
Forced US allies to source from Pfizer's Belgium plant instead.
https://www.lawfareblog.com/understanding-bidens-invocation-...
Nothing in there on vaccine export but one would assume it is implied.
* protective equipment and ventilators
* specifically 3M and companies for masks and ventilators
* testing swabs
* diagnostic systems and assays
---
https://web.archive.org/web/20200318233011/https://www.white...
> Accordingly, I find that health and medical resources needed to respond to the spread of COVID-19, including personal protective equipment and ventilators, meet the criteria specified in section 101(b) of the Act (50 U.S.C. 4511(b)).
Note that this is the executive order for allowing the Secretary of Health and Human Services to do things...
> (c) The Secretary of Health and Human Services shall issue such orders and adopt and revise appropriate rules and regulations as may be necessary to implement this order.
It wasn't specifically saying "you, company, make this."
---
https://www.politico.com/news/2020/04/02/trump-expands-dpa-o...
> President Donald Trump on Thursday invoked the Defense Production Act to push 3M and six major medical device companies to produce protective masks and ventilators needed for the coronavirus outbreak, bowing to weeks of pressure to expand the federal government’s use of the emergency statute.
---
https://www.politico.com/news/2020/04/19/trump-dpa-testing-s...
> President Donald Trump will use the Defense Production Act to compel an unnamed company to produce 20 million more coronavirus testing swabs every month — weeks after labs and public health officials started warning that shortages of these swabs were hurting efforts to ramp up testing nationwide
---
https://www.hhs.gov/about/news/2020/08/20/trump-administrati...
> These acquisitions will fulfill a large-volume purchase of diagnostic systems and assays for COVID-19 testing and will expedite shipments of these systems and assays to every nursing home certified by the Centers for Medicare & Medicaid services (CMS) with a Clinical Laboratory Improvement Amendment (CLIA) Certificate of Waiver – approximately 14,000 nursing homes – in the United States.
---
Further reading:
https://en.wikipedia.org/wiki/Defense_Production_Act_of_1950...
Additionally - https://www.bloomberg.com/news/articles/2020-12-08/trump-vow...
> Trump raised the specter of invoking the Defense Production Act -- which allows the president to require companies to prioritize contracts deemed essential for national security -- if the U.S. struggles to obtain the vaccine for its citizens.
> “If we have any problems, we will be instituting the Defense Production Act and make sure we don’t have any problems,” he said.
Trump did not invoke the DPA for vaccines.
Some people might say that deliberately accelerating the pandemic wasn't the best use of the DPA, but he certainly did use it.
https://www.lawfareblog.com/understanding-bidens-invocation-...
If it nationalized the factories, or seized supply it hadn't ordered, I might consider it the bad guy. But irrespective of who gets the vaccines first, the EU has already bought the some portion of the supply.
I understand that viewpoint but feel like the long term consequences politically would be too high. We live in a globalised world where most of the richest countries do little of their own manufacturing. If we start blocking exports in times of crisis the foundations of that system would be damaged.
Nationalization etc. happens on the national level only.
I would argye that the EU merits government status, given the degree to which it dictates standards in the eurozone. Even though it is fairly weak, and lacks enforcement capacity on its own, my understanding is that the EU as a body has the capacity to set standards for the block as a whole, restricting export of certain goods like the vaccine for example. I could be wrong, though?
The UK purchased right of first refusal on the first 100million doses of Oxford/AZ produced in the UK factories that they funded.
The EU also funded factories (in the EU) but did not purchase right of first refusal only best efforts contracts.
The USA has a full ban on exports till they are ready to export.
The UK is not blocking exports. The EU were free to conclude contracts with the (not very productive) UK manufacturers at the same time HM government was doing so.
nope, the UK and the US have a "first us, then the rest" policy for exports, that the EU does not.
https://www.repubblica.it/cronaca/2021/01/26/news/interview_...
Instead, there are multiple steps along the way, that matter much more than some singular data point of a very long contract process that has many stages.
The Vaccine Alliance did a contract with AstraZeneca before the UK. The Alliance was Germany, Italy, Netherlands and France.
AstraZeneca says this "doesn't count". I believe this was around 1 month before the UK agreement was signed.
Here's another article that goes over it https://www.politico.eu/article/europe-coronavirus-vaccine-s...
And here's the press release up on Reuters https://www.france24.com/en/20200613-covid-19-france-italy-g...
https://uk.ambafrance.org/Inclusive-Vaccines-Alliance-reache...
And in the French embassy..
You're being fed BS. AZ signed with the Alliance, that contract was turned over to the EU comission. AZ is most likely caught up in giving their vaccine to the UK first and they are lying constantly. See the controversy on their efficacy in the US.
I also tried the two France24 links. They're both 404 Not Founds. The final link is also a 404. That's a bit odd. Where are you getting these links from? At any rate, the result is you've not provided any evidence that AZ is lying, which is a very bold claim to begin with. Why would they do that? AZ is part Swedish and has a Greek CEO, it's not like they're a 100% pure British firm of tub-thumping Brexit supporting patriots who inexplicably don't want to supply Europe with vaccine. Although by now I wouldn't be surprised if they're thoroughly sick of the EU and its games.
Meanwhile the EU has:
a) The motive to lie.
b) A track record of doing so repeatedly, a completely undeniable one.
It's ridiculous how often the EU or leaders of members states have said totally untrue things about this vaccine or the UK, I made a list at some point (see my old comments) and within a week there'd been another two lies coming out of Europe. I'm not the one being fed BS here - in many of those cases Europe's leaders have already admitted they'd said untrue things!
If you assume the EU has a motive to lie and the UK and AZ does not, you are immediately demonstrating bias.
Relevant quote:
Asked about the Halix situation, the commission said on Friday that the EMA was ready to fast-track authorisation of new production facilities once it received an application and the necessary information from AstraZeneca.
Certainly the UK MHRA have been working closely with the companies to move the process along very quickly, as has been confirmed by both the government and the companies themselves.
I'm curious to know what's really going on at the Halix plant.
In the absence of further guidance and given the EU's hostility to them so far, AZ may be waiting to ensure it has all its ducks in a row before submitting.
In the UK the regulator was willing to do partial processing of applications in parallel with the project being executed, which isn't normal and poses obvious complexities, but can speed things up when latency is what matters most. If the EMA hasn't indicated any willingness to do that, and it's not the first time they've come up with this "we're waiting for submission" business, then it may be causing artificial delays.
It is in AZs interest to not start the process which would make the factory available for EU, where AZ is not willing to deliver at this time. (Instead, they ship doses even from the EU factories to UK and elsewhere.)
Given this, you would need something concrete to back your speculation to the contrary.
It's not in AZ's interest to keep an expensive factory idled in an environment of unprecedented demand, obviously. They want to sell vaccine to whoever will take it. AZ is "unwilling" to deliver to the EU because it has signed contracts putting other countries first and they are able to consume the entire supply. Once the UK is done, they will suddenly become "willing" (if such a term makes sense when contracts are involved) to deliver to the EU as well.
So to be clear, you are describing factual statements as speculation (which is wrong) and then making spurious claims about AZ/EMA's claimed interests instead of what they're actually doing.
"Rolling review" is the term I've seen typically used for the process that you described, and Wikipedia has references for various rolling reviews by EMA starting with the following: "In October 2020, the Committee for Medicinal Products for Human Use (CHMP) of the European Medicines Agency (EMA) started 'rolling reviews' of the vaccines known as COVID-19 Vaccine AstraZeneca (ChAdOx1-SARS-CoV-2) and Pfizer-BioNTech COVID-19 Vaccine (BNT162b2)." https://en.wikipedia.org/wiki/History_of_COVID-19_vaccine_de...
1. I voted remain and would again.
2. Everybody I’ve spoken to that actually lives in the EU agrees the EU has screwed up - it seems to mostly be remain voters who can’t move on who disagree with this.
3. If you have evidence contrary to my comment share it, keep the personal attacks to yourself.
Whichever country is contractually at the front of the line will have their order fulfilled first/according to the terms of the contracts.
The EU wasted months negotiating lower prices and then took longer with approvals.
There is no good guy or bad guy (at least until the UK or EU blocks exports preventing execution of the private contracts - at that point the country blocking the exports becomes the bad guy).