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California Enforces Supply Chain Disclosure Law

By Chandri Navarro
May 6, 2015
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The California Attorney General’s (AG) office recently issued letters to more than 1,700 companies listed as manufacturers or retailers on their California state tax returns requiring them to notify the AG’s office that they are, or are not, in compliance with the California Transparency in Supply Chains Act (the Act).

These letters appear to be an attempt to enforce compliance with the Act, which became effective on January 1, 2012, but has received little attention outside of the traditional retail sector. The letters have been received by companies across a vast array of industries that happen to have sufficient sales in California, catching many companies and their general counsel’s by surprise. The Act requires companies to make certain disclosures about their efforts to avoid forced and child labor in their supply chains. Any company that identifies as a retail seller or manufacturer on its California tax return and earns annual worldwide gross receipts greater than US$100 million must comply with the law. Violations of the Act can result in an action brought by the Attorney General for injunctive relief.

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Photo of Chandri Navarro Chandri Navarro

Partner, Washington, D.C.

Chandri Navarro works with companies, multinationals, trade associations, and governments on customs and trade law and policy, trade compliance matters, free trade negotiations, litigation, and legislation. Chandri helps clients resolve trade issues before the U.S. Customs and Border Protection (CPB)…

Partner, Washington, D.C.

Chandri Navarro works with companies, multinationals, trade associations, and governments on customs and trade law and policy, trade compliance matters, free trade negotiations, litigation, and legislation. Chandri helps clients resolve trade issues before the U.S. Customs and Border Protection (CPB), Office of the U.S. Trade Representative, Department of Commerce (DOC), U.S. Congress, and the Court of International Trade.

For over 20 years, Chandri has advised clients on customs and trade issues in many different countries and before foreign trade and customs agencies. She helps clients evaluate risks, identify potential problems, and resolve them in a practical and efficient manner when they do arise. She works with companies to create effective trade compliance programs, and to find business opportunities in their import/export transactions around the world.

Chandri advises clients on tariff classification, customs value, country of origin, labeling, trade preference programs, free trade agreements, and trade compliance programs. She also helps clients respond to CPB and other government agencies on matters affecting imports. She works with companies in reviewing contracts, agreements, and mergers and acquisitions (M&A) documents to help protect clients from trade compliance risks and successor liability.

Since her time as a U.S. State Department Security-Cleared Industry Adviser during the NAFTA negotiations, Chandri has helped companies and U.S. and foreign trade associations navigate the intricacies of rules of origin, tariff phase-out schedules, and cumulation provisions in trade negotiations.

Fluent in English, Spanish and French, Chandri is a sought-after speaker around the world on issues affecting importers and exporters.

Read more about Chandri NavarroEmail
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  • Posted in:
    Administrative
  • Blog:
    Focus on Regulation
  • Organization:
    Hogan Lovells
  • Article: View Original Source

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