International Index

Click on a topic below to jump down the page to its summary and a direct link to its Digital Compoundings article.
JAN 2019 / V69 / No1

International Insights  –  Iran and Nicaragua at Year's End: US Sanctions Update
James Eggenschwiler provides an update on the impact of growing sanctions against Iran and Nicaragua on manufacturing. This article discusses the executive order issued by Trump and the resulting direct and indirect burdens on any company engaged in commercial activity with either of these markets. Eggenschwiler describes the essential steps to avoid violating this executive order and explains that certifications of compliance along are categorically insufficient. #Trump #Sanctions #Iran #Nicaragua 

DEC 2018 / V68 / No12

International Insights  –  The New Korea Biocides Law: K-BPR
James Eggenschwiler provides an update on the new Korean biocides law titled "K-BPR" amidst ongoing changes to the changes to the regulatory process in the form of K-REACH. This article details the aspects of the new law related to industrial products including registration requirements, grace periods, and pre-notifications. Many of the implementation details remain uncertain and this discussion is an excellent place to develop a foundational understanding of the law before the enforcement date commences. #K-BPR #K-REACH #Korea #MOE

NOV 2018 / V68 / No11

International Insights  –  The 2019 K-REACH Preregistration Window
James Eggenschwiler follows up on his previous article detailing the redesign of K-REACH with a piece focused solely on the required preregistration window. The new law requires the registration of all existing chemical substances manufactured or imported at one ton per year during prescribed dates based on tonnage bands or chemical hazard profiles. This information is invaluable because failing to properly file a preregistration during the window effectively closes the market in Korea for the given chemical substance until it has been registered and approved. #K-REACH #Korea #Preregistration #OR

OCT 2018 / V68 / No10

International Insights  –  New US Policy On Iran: The Perilous Sanctions Landscape
James Eggenschwiler discusses potentially crippling penalties related to commercial activity with Iran on the horizon. This article calls attention to the controls needed to survive the threatening commercial and geopolitical landscape. This information is very important because safety begins with having the ability to control these dangers associated with prohibited commercial activity. Once you have controls in place, these Iran penalties or any future sanctions can be addressed with relative ease and expediency. #Iran #Sanctions 

Counsel Compound  –  Lubricants and Additives: Exclusion from Chinese Tariffs? 
Jeff Leiter reviews the process for seeking exclusion from the Chinese tariffs imposed by the U.S. Trade Representative (USTR) through the Trump administration. This article lays out the exact steps necessary to preparing an exclusion request for each product depending on the extent that your company is directly affected by the new duties. These resources will be invaluable to companies in their efforts to compile the necessary information to mitigate the impact of these tariffs. #Trump #China #Tariffs

SEP 2018 / V68 / No9

International Insights  –  Explaining the Korea Chemical Control Act
James Eggenschwiler explains the Chemical Control Act (CCA) which is often overlooked in discussions of the Korean regulations because it is overshadowed by K-REACH. The CCA regulates use, handling, and related disclosures and licensing concerning chemical products and related substances placed on the Korean market. In particular this article considers the law's impact on foreign suppliers by obligating them to fully disclose chemical ingredients. Eggenschwiler examines the limited but effective alternatives that allow importers to directly and confidentially disclose to Korean regulators. #CCA #Korea #K-REACH #SDS #GHS #OR 

AUG 2018 / V68 / No8

International Insights  –  K-REACH Redesigned: Seoul's "Do-Over" for 2019
James Eggenschwiler explains the long-awaited amendments to K-REACH that were recently passed by South Korea. This article catalogs these changes including pre-notification of all existing chemicals, relaxed registration burdens on smaller amounts of new chemicals, the elimination of the annual reporting responsibility, and the replacement of the Toxic Chemical Control Act (TCCA) with the Chemical Control Act (CCA). These updates to the regulatory system were intended to replicate the overall design of the EU-REACH. This article is a great resource for reviewing the numerous and complex changes in the ongoing chemical management under K-REACH in an accessible format. #K-REACH #EU-REACH #TCCA #CCA #Korea #EU

JUL 2018 / V68 / No7

International Insights  –  Commercial Risk Goes Viral After the Latest US Sanctions on Russia
James Eggenschwiler discusses the significant manufacturing risks associated with the unprecedented scope and reach of the new sanctions against Russia issued by the Office of Foreign Assets Control (OFAC). This article lists the twelve designated companies and examines the direct and indirect scope of their commercial activity. The immediacy of these sanctions cannot be overstated and any company with undivested ties to these sanctions must seek counsel straightaway to examine their options. Eggenschwiler makes it clear that all commercial dealings now require denied party screening and extra caution. #OFAC #Sanctions #Russia

JUN 2018 / V68 / No6

International Insight  –  EU REACH Registration Period Ends
James Eggenschwiler discusses important issues that arise for registrants following the European Union's (EU) Registration, Evaluation Authorization, and Restriction of Chemicals (REACH) deadline. This article contains strategies for dealing with a variety of these issues including increased substance identity profile (SIP) scrutiny by the European Chemicals Agency (ECHA), enforcement of Extended Safety Data Sheets (eSDS), and maintaining registrant supply chain integrity. Eggenschwiler reminds registrants to stay vigilant and preserve record-keeping compliance following the EU REACH deadline in order to properly navigate the complex enforcement agenda. #REACH #EU #SIP #ECHA #eSDS

MAY 2018 / V68 / No5

International Insight  –  Where to Go With a Flat Global Market
Lam Lye Ching catalogs expert recommendations for finding opportunities in the relatively flat global lubricant market. This article contains valuable information about volume growth markets such as Africa and South America and quality lubricant markets like Asia and the Middle East. Becoming familiar with these developing lubricant markets is the first step to achieving successful industry growth in a flat global market. #FlatMarket #Asia #MiddleEast #Africa #SouthAmerica

Counsel Compound  –  Tariffs and Trade
Jeff Leiter discusses the impact of Trump's recently announced plans to impose tariffs on Chinese imports will have on manufacturing. This article reflects on the possibility of an all-out trade war with China and the preceding concerns of U.S. manufacturers including ILMA members. Leiter examines these trade concerns from a reassuring and informative historical context. #China #Trump #Tariffs #Trade

APR 2018 / V68 / No4

International Insight  –  Post-Toxic Substances Control Act Inventory "Reset" Importer Dilemmas 
James Eggenschwiler provides useful tips for navigating the complicated process of complying with the Toxic Substances Control Act (TSCA). This new ruling issued by the Environmental Protection Agency (EPA) requires importers to report essential information about their substances. These self-disclosures become significantly more challenging in circumstances where the Audit Policy is unavailable. This article helps you understand the process which is essential to avoid potential penalties for failing to achieve the required compliance. #TSCA #EPA #AuditPolicy

MAR 2018 / V68 / No3

International Insight  –  The Tide Has Turned: US Toughens Enforcement of Forced-Labor Imports Ban
James Eggenschwiler examines the newly strengthened forced-labor imports ban and the potentially disastrous outcome of failing to comply. The U.S. Customs and Border Protection (CBP) recently established presumptions concerning use of forced labor that must be effectively disproven by the importer. Unfortunately, the evidence required to establish forced-labor involvement has been significantly relaxed and Withhold Release Orders (WROs) are being issued more frequently. This article describes the standard procedure for challenging a forced-labor accusation, the penalty process once initiated by the CBP, and the appropriate controls necessary to avoid purchasing tainted commodities. #CBP #WROs

FEB 2018 / V68 / No2

International Insight  –  Lubricant Business Benefits from IT
Lam Lye Ching discusses the many ways in which the lubricant industry is benefiting from information technology (IT) solutions. Some of the innovative IT solutions mentioned in this article include enterprise resource planning (ERP), sales communication networks, artificial intelligence (AI), cloud storage, and "internet of things" (IoT) integration. Learning more about how these software platforms and using that knowledge to develop intelligent applications can provide answers, predictions, and recommendations to your customers and employees. #IT #ERP #IoT #AI

Counsel Compound  –  Weathering the "Storm" After a Storm
Jeff Leiter describes the process of identifying, mitigating, and minimizing risks from flooding. The Federal Emergency Management Agency (FEMA) recommends using a hazard and operability (HAZOP) analysis as a risk management tool. The dangers of companies not being adequately prepared for a natural disaster were fully realized during Hurricane Harvey. Leiter suggests that ILMA members' facilities integrate HAZOP into their existing emergency response plans. The details in this article should not be overlook because failure to properly prepare for disasters can result in criminal investigations by governmental authorities. #FEMA #HAZOP #SPCC #Emergency

JAN 2018 / V68 / No1

International Insight  –  European Market Steadily Flat, but With Niche Opportunities
Lam Lye Ching remarks that despite Europe being the third largest lubricant market there are still niche opportunities for lubricant blenders even while the market remains flat. This article contains useful information, provided by oil and lubricant industry consultancies, for identifying and seizing these niche opportunities. Additionally, the article identifies challenges for lubricant blenders looking to navigate this market including developing industrial production technologies, REACH registration deadlines, and strict environmental regulations. #EU #REACH

Counsel Compound  –  How is Regulatory Reform Shaping Up Under President Trump?
Jeff Leiter revisits Trump's deregulation efforts as the first year of his presidency ends. These efforts include the elimination of certain regulations, the exemption of more entities from particular rules, and the reduction of compliance costs in federal rules. The focus of this article is primarily on the long-term impact these efforts will have on ILMA members. #Regulations #Trump