Earlier this week, our firm sponsored a panel discussion entitled “Export Compliance for Aerospace & Defense Firms – What the OEMs Expect from Their Supply Chain” as part of Connecticut Export Week 2018.  Joanne Rapuano, Counsel in Robinson & Cole’s Trade Compliance practice, moderated the discussion.  The panel included Matthew Borman, Deputy Assistant Secretary of Commerce for Export Administration and trade compliance officers from major aerospace and defense manufacturers.

Mr. Borman discussed something on the minds of many manufacturers, i.e., the new steel and aluminum tariffs.  He mentioned that the Department of Commerce has published information regarding those seeking exclusions from the new tariffs.  As mentioned by the Department of Commerce, in determining whether to grant an exclusion, “the Secretary will consider whether a product is produced in the United States of a satisfactory quality or in a sufficient and reasonably available amount.”  Significantly, any requests for exclusions will be published for the public to see and U.S. parties can file objections.  We have already started to receive calls about applying for exclusions.  Yet, even if your company does not apply for one, you should monitor the public filings to see whether your competitors are doing so.

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Photo of Jeffrey White Jeffrey White

I am a partner at Robinson+Cole who handles corporate compliance and litigation matters for both domestic and international manufacturers and distributors that make and ship products around the world. My clients have ranged from publicly traded Fortune 500 companies to privately held and/or…

I am a partner at Robinson+Cole who handles corporate compliance and litigation matters for both domestic and international manufacturers and distributors that make and ship products around the world. My clients have ranged from publicly traded Fortune 500 companies to privately held and/or family owned manufacturers. For those looking for my detailed law firm bio, click here.

I am often asked why I have focused a large part of my law practice on counseling manufacturers and distributors. As with most things in life, the answer to that question is tied back to experiences I had well before I became a lawyer. My grandfather spent over 30 years working at a steel mill (Detroit Steel Company), including several years in its maintenance department. One of my grandfather’s prime job duties was to make sure that the equipment being used was safe. In his later years, he would apply those lessons learned in every project we did together as he passed on to me his great respect and pride for the manufacturing industry.

Because of these experiences, I not only feel comfortable advising executives in a boardroom, but also can easily transition to the factory floor. My experience has involved a range of industries, including aerospace and defense, chemicals, energy, pharmaceuticals and life sciences, nutritional and dietary supplements, and retail and consumer products. While I have extensive experience in litigation (including product liability and class actions), I am extremely proactive about trying to keep my clients out of the courtroom if at all possible. Specifically, I have counseled manufacturers and distributors on issues such as product labeling and warranties, product recalls, workplace safety/OSHA, anti-trust, and vendor relations, among other things. I always look for the business-friendly solution to a problem that may face a manufacturer or distributor and I hope this blog will help advance those efforts.