The increasing prominence of domestic and international trade regulation and global demands for socially and environmentally responsible trade place a heavy burden on manufacturers and importers. As requirements change, companies must implement strategies to remain at the cutting edge of these changes and to develop and implement compliance programs. Mowry & Grimson attorneys work with both domestic and international clients to ensure that their goods and practices fulfill the private and governmental quality and safety standards.
In 2008, Congress began amending the Lacey Act, the nation's oldest wildlife protection law, to address the global plight of illegal logging. In addition to strict prohibitions on the trade of illegally harvested plants and plant products, the amendment requires that importers file a complex declaration upon entry for all goods that include any amount of plant or plant product. Mowry & Grimson attorneys were among the first members of a coalition representing importer rights and interests in negotiations with members of Congress and federal government agencies regarding the scope and implementation of the Lacey Act amendment. Our attorneys have aided both domestic and international manufacturers and importers in creating and implementing programs to comply with the Lacey Act amendment.
The Consumer Product Safety Improvement Act of 2008 (CPSIA) and related Consumer Product Safety Commission rules and regulations impose a vast array of testing, certification and documentation requirements on many different types of consumer products. These requirements apply to products manufactured domestically and those imported into the United States for sale and carry steep monetary and potentially criminal penalties for violation. Mowry & Grimson attorneys counsel clients on how to comply with these and many other consumer product safety requirements and represent companies charged with violating the CPSIA and related laws.
As part of the Dodd-Frank Wall Street Reform and Consumer Production Act, the U.S. Securities and Exchange Commission requires public companies to disclose the presence of "conflict minerals" in the their manufacturing process. Conflict minerals are designated as such because of human rights abuses associated with their mining operations and are defined as tungsten, tantalum, tin and gold originating in the Democratic Republic of the Congo and adjoining countries. These minerals are used in a wide range of products, most commonly electronics, jewelry, tools, automotive parts and lighting, but can also be found in such unexpected places as furniture with electronic components. Mowry & Grimson assists clients with supply chain auditing and compliance to determine if and how companies must comply with these rules.
In additional to federal regulation of imported goods, some states impose ground-breaking requirements on the trade of goods. California is frequently the trend-setter in this regard. For example, the California Air Resource Board imposes stringent limits for formaldehyde emitted from composite wood products; the California Transparency in Supply Chains Act requires companies to disclose their efforts to eradicate slavery and human trafficking in their supply chains; the California Bureau of Electronic and Appliance Repair, Home Furnishings and Thermal Insulation regulates flammability testing of furniture and California Proposition 65 requires businesses to disclose certain chemicals in the products they purchase or that are released into the environment. Mowry & Grimson works with clients and industry groups to ensure that their sales comply with these California laws and the rules of all jurisdictions where they operate.