Last updated: 6 August 2026
1. Our commitment
ECAM Trade LLC conducts its sourcing, manufacturing and distribution activity in accordance with the export control, sanctions, customs and product safety laws of the jurisdictions we operate in — principally the United States, the Republic of Türkiye, the People's Republic of China, and the destination markets our clients ship to.
We will decline or discontinue a transaction where compliance cannot be established. This applies regardless of the commercial value of the order, and it is not negotiable.
2. Sanctions and restricted party screening
Before we onboard a supplier, client or logistics partner — and again before a shipment moves — we screen the parties involved against the restricted and denied party lists that apply to the transaction, including:
- The US Treasury OFAC Specially Designated Nationals (SDN) and Consolidated Sanctions lists
- The US Commerce BIS Entity List, Denied Persons List and Unverified List
- The US State Department Debarred List
- EU and UK consolidated sanctions lists, where the transaction touches those jurisdictions
Screening covers the counterparty, its known beneficial owners, the end user where different, and the intermediate consignees, banks and vessels in the shipping chain. A positive or ambiguous match stops the transaction until it is resolved.
3. Export controls and end use
The goods we handle are predominantly consumer and industrial chemical formulations, cleaning and household products, automotive care products, packaging and related retail goods. These are ordinarily classified EAR99 under the US Export Administration Regulations and are not controlled munitions or dual-use items.
We nonetheless apply end-use and end-user diligence, and will not proceed where we know or have reason to believe that goods are destined for a prohibited end use, a prohibited end user, or an embargoed destination — or where a transaction shows signs of diversion, such as a mismatch between the stated end use and the quantity or destination, unusual routing, or a customer unwilling to identify the end user.
Where a specific product does carry a control classification, we identify it and obtain the required licence before shipment.
4. Customs classification, valuation and origin
Accurate declarations are a legal obligation on the importer of record, and we treat them as one:
- Classification — we determine the correct HS/HTS classification for each product, and support clients and their brokers with the technical specification needed to substantiate it.
- Valuation — declared values reflect the true transaction value, including assists and dutiable additions where they apply. We do not undervalue goods, and we will not participate in split or duplicate invoicing.
- Country of origin — origin is determined by where substantial transformation actually occurs, and is marked and declared accordingly. We do not facilitate transhipment intended to disguise origin or evade duties, antidumping orders or countervailing duties.
- Documentation — commercial invoices, packing lists, certificates of origin, bills of lading and product certificates are prepared to match the goods actually shipped.
5. Product regulatory conformity
Private label and distribution programs carry regulatory obligations in the destination market. Depending on the product and market, our scope includes supporting:
- Safety Data Sheets and hazard classification under GHS, and OSHA HazCom or CLP labelling as applicable
- US FDA, EPA or CPSC requirements where a formulation or product category falls within their scope
- EU REACH and detergent regulation requirements where goods enter the EEA
- Labelling content — ingredients, net contents, warnings, responsible-party details and language requirements
- Packaging, transport classification and dangerous-goods documentation where relevant
- Barcode, case marking and retailer-specific packaging standards
Responsibility for final regulatory sign-off in a destination market sits with the party placing the product on that market. We supply the documentation, testing and specification needed to support it, and will say plainly when a requirement falls outside our scope.
6. Supply chain due diligence and forced labour
We source through direct factory relationships rather than trading listings, which is what makes meaningful diligence possible. Our supplier onboarding includes ownership and restricted party screening, facility assessment and documented quality systems, and we conduct in-person visits and inspections at the production sites we use.
We require our suppliers to operate free of forced, bonded and child labour, and we support clients subject to the US Uyghur Forced Labor Prevention Act (UFLPA) and comparable regimes with the supply chain traceability documentation those laws require. A supplier that will not provide traceability is not a supplier we keep.
7. Anti-corruption
We do not offer, pay, solicit or accept bribes or facilitation payments, whether directly or through an agent, in any market. This reflects our obligations under the US Foreign Corrupt Practices Act and equivalent legislation, and applies to dealings with customs officials, inspection bodies and commercial counterparties alike.
8. What we ask of you
Compliance is a shared obligation. When you work with us, you agree to:
- Identify the true end user and end use of the goods, and tell us if either changes
- Provide accurate company, ownership and destination information
- Not re-export, divert or resell goods in breach of applicable export control or sanctions law
- Meet the regulatory requirements of the market in which you place the product
9. Raising a concern
If you believe a transaction, supplier or shipment involving ECAM Trade raises a compliance concern, tell us. Write to info@ecamtrade.com with “Compliance” in the subject line. We investigate every report, and we do not retaliate against anyone who raises one in good faith.
10. Status of this page
This page describes our internal standards and commitments. It is a statement of policy, not legal advice, and it does not vary the terms of any signed agreement. Applicable law is what governs any given shipment, and it changes — where a specific transaction raises a question, we resolve it against the rules in force at the time.