The last two places you ever want your name to appear.

Companies who import or export are governed by regulatory regimes which grow more complex by the day.  Because many companies do not open their doors as an importer or an exporter specifically, they make the transition there.  Perhaps they were purchasing domestically and pricing pressure caused them to look overseas.  Perhaps they looked at the National Export Initiative as a means to find new business and expand their client base beyond the US shores.

But what happens when something goes wrong?  With the passage of the CPSIA in 2008, the Consumer Product Safety Commission has grown more forceful in regulating imports as well as the mechanism of initiating a product recall.  This is the first of our two "places you never want your name to appear."  A product recall is something that requires a two-pronged strategy of damage control and positive spin.  The most recent recall belongs to Graco, who have the expense and publicity of dealing with two million problematic strollers.

The lesson is that while there's no way to one hundred percent insulate from such a thing, the question becomes what can a company do concurrently with the recall to insure that their brand isn't irreparably damaged.

The second place to avoid appearing is on the list of companies who have pleaded guilty to an export violation and paid some sort of criminal or civil penalty for it. The Bureau of Industry and Security is rather proud of the people they get to pay up and loves to issue press releases about them all.  


Staying off the radar screen of these agencies requires advanced planning, due diligence, written compliance instructions and the buy-in from top management.  It is everyone's responsibility to understand that much like weighing the risks of when to disclosure on a Customs matter, hard questions must be asked about when is it appropriate to come forward in advance or be dragged reluctantly and belatedly in front of the public at the risk of reputation and brand.