International Trade Task Force

When a company decides to market products globally, a large and sometimes bewildering set of regulations must be observed. Gaining a thorough understanding of applicable regulations, which can vary on a country-by-country basis and are subject to change, is critical for success. The International Trade Task Force was established to provide members of the Hydraulic Institute (HI) and the Valve Manufacturers Association (VMA) with the information and the clout they need to negotiate the labyrinth of international trade regulations as they apply to the pump and valve industries.

In August of 2005, the HI Board of Directors approved a resolution to establish an Export Control Task Force with an annual fee for each participating member company. In 2006 the scope of the task force was expanded to include valves and members of the Valve Manufacturers Association were invited to participate.  The committee meets approximately once per month by teleconference to discuss topics with the appointed Legal Counsel and to hear speakers from the various agencies including the Department of Commerce, Bureau of Industry Security, and Nuclear Regulatory Commission.

• Charter

  Represents international trade (i.e. export control, customs, international anti corruption) interests of HI and VMA members who have chosen to affiliate with the International Trade Task Force (ITTF) for its stated purposes. Functions include education, best practices, and government liaison.

• Scope

  Pumps, valves, pump and valve components* and pumping systems subject to international trade regulation by the U.S. government.

  *Export controls cover complete products and certain pump casings, pump bodies, casing liners, impellers, rotors and jet pump nozzles, and valve bodies and preformed casing liners for valves.

• Membership Eligibility

  Open to any HI or VMA member company, and their duly appointed representative(s) with expertise or interest in international trade compliance, based on payment of an annual fee to support professional export control representation in Washington, D.C. and associated administrative efforts of HI staff in supporting the committee. Representation on the International Trade Task Force is limited to HI and VMA member companies as a unique benefit of their association membership.

• Purposes
  1. Mitigate the effect of export controls on the U.S. pump industry through professional Interaction with the U.S. Department of Commerce, Bureau of Investigative Services to the following ends:
     • Assure licensing officials of BIS and other export control agencies that HI, VMA and their members are very much aware of the applicable regulations and support efforts to strengthen U.S. and international security in an effective fashion.
     • Address with BIS the needs of the pump and valve industries for timely processing of the significant increase in export license applications caused by the April 14, 2005 broadening of the country scope of existing controls.
  2. Work to reduce the currently perceived need to focus heavy enforcement efforts on the industries by working with member companies to enhance compliance and by demonstrating to the agency that HI members are working to disseminate information about export controls and working to enhance industry-wide compliance.
     • Conduct updates and timely informational briefings for members, via the web and/or at HI/VMA meetings and through ITTF meetings to maintain high-level and timely information on the subject of export controls and efforts with BIS to mitigate their impact on the U.S. pump and valve manufacturing industries.
  3. Continue to organize HI/VMA members to provide collective support, principally scientific and engineering support, to BIS personnel dealing with proposals that would alter export controls on pumps. In particular, Task Force members and others with industry expertise, as designed by the Task Force, would be called upon to provide information to BIS to support the agency’s efforts to reach the most effective possible international agreements regarding pump export controls and to implement internationally agreed controls in U.S. law as effectively as possible.
  4. Represent the collective interests of participating HI/VMA members, anonymously, before BIS to identify issues of concern or to resolve common questions of concern poised by at least 1/3 of the participants in the Task Force on interpretations of export control regulations for particular types of products and/or technology.
  5. The Task Force would try to work with BIS and others in the export control community to open the door to substantive discussions about the foreign availability of controlled pumps, valves and components the effectiveness of the regulations, and the potential need to alter the regulations in a way that they are still effective, but impose less of a burden on the industry. Such discussions may include how to refine the controls so that they do not capture products that are not of true concern to the agency, or to encourage efforts to make the regulations more broadly applicable around the world so that U.S. producers, distributors, and others are not severely disadvantaged.
  6. Work with U.S. government agencies, including U.S. Customs and Border Protection, the Department of Justice, the Defense Department and other international trade professionals to provide timely information updates regarding critical areas of international trade regulation and best practices for dealing with international trade.
  7. Task Force members, its counsel and staff are subject to the Bylaws, Anti-Trust Guidelines and all policies and procedures of the Hydraulic Institute. Any policy issues shall be developed within the Task Force, and with appropriate counsel, and approved by the Board of Directors of the Hydraulic Institute or its designated representative, the Vice President, Member Services to which the Chair and/or Co-chairs of the International Trade Task Force shall report.
• Regulatory and Trade Updates

  Russia / Ukraine Sanctions

  As the situation rapidly changes, please visit https://www.kelleydrye.com/russia-sanctions for the most recent updates and ‘explainers’ regarding U.S., EU, UK and other country trade sanctions against Russia in response to the invasion of Ukraine.

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