The European Court’s ruling in the ‘substances in articles’ case FDC and FMB v Ministre de l’ecologie, du development durable et de l’energie will extend aspects of EU chemical law compliance. Going forward, importers and suppliers doing business in the EU will be required to have increased oversight and understanding of the chemical compositions of … Continue Reading
A month after the U.S. Department of Defense issued a final rule (“DoD rule”) that impacted the defense supply chain by requiring certain contractors to detect and report counterfeit electronic parts (discussed here), the Federal Acquisition Regulation (“FAR”) Council published a new proposed rule to greatly expand counterfeit reporting obligations. The proposed rule sets forth … Continue Reading
The U.S. Department of Defense (“DOD”) recently issued a final rule that will significantly impact the defense supply chain. The new rule, effective May 6, 2014, implements the provision in Section 818 of the fiscal year (FY) 2012 National Defense Authorization Act (“NDAA”) related to the use of counterfeit electronic parts in DOD products. Specifically, … Continue Reading
Companies with global supply chains are rapidly imposing detailed standards for their suppliers that go way beyond the traditional performance and quality specifications. Until recently, the most obvious categories of concerns for global manufacturers were rules of origin for products and parts for purposes of customs valuations and treaties, heightened by protectionist legislation such as … Continue Reading
