Trade Compliance Policy

1. Purpose and scope

VMA Global Trade LLC advises United States buyers who purchase from foreign manufacturers. This policy applies to our staff, our agents and inspectors in China, and to every client engagement. Instructing us to begin work means accepting it.

2. Who is responsible for what

• You are the importer of record. The legal duty to enter goods correctly, exercise reasonable care under 19 U.S.C. § 1484 and pay the correct duties is yours.
• We advise, verify and document. We tell you what the product needs, collect the evidence at origin and review it before shipment.
• The customs entry is filed by a licensed customs broker engaged by you. We are not customs brokers and we do not file entries.
• Nothing in this policy transfers your legal obligations to us, and nothing in it reduces our duty to refuse work that would break the law.

3. Counterfeits and intellectual property

This is our first screen, before price and before feasibility.

• We refuse counterfeits, replicas, "inspired by" copies, unauthorized branded parts and unlicensed characters, logos or artwork.
• We check the product against known brand designs and registered marks before quoting a project, and we decline where the position is unclear.
• Counterfeit goods are seized and destroyed by U.S. Customs and the importer of record faces penalties. No margin justifies that exposure.
• Where you supply artwork or a design, you warrant it is yours or licensed to you, and you indemnify us under our Terms of Service.
• Where a factory offers to copy a competitor's product, we tell you and we decline that route.

4. Product safety and labeling

• Country of origin marking under 19 U.S.C. § 1304, on the product and where required on the retail packaging, confirmed before production closes.
• Children's products require CPSIA third-party testing, a Children's Product Certificate and permanent tracking labels. Without them we do not let a project proceed.
• Electronics that emit radio frequency require FCC marking and a supplier declaration of conformity.
• Cosmetics and personal care require compliant U.S. ingredient labeling in English, and facility registration and product listing under MoCRA where applicable.
• Food-contact materials require documentation of the resins, coatings and additives used.
• Textiles and apparel require fiber content, country of origin and care labeling, applied at origin.
• Lithium batteries follow IATA and carrier rules. Loose cells and standalone power banks are not accepted for air transport.
• We collect the certificates and test reports available from the manufacturer and pass them to you. They are evidence for your file, not a warranty from us that the product complies.

5. Projects we will not take

• Counterfeit, replica or infringing merchandise.
• Weapons, ammunition, their parts and accessories.
• Prescription drugs, controlled substances, vapes, nicotine and cannabis products.
• Supplements or devices making medical or health claims that would require FDA clearance the client does not hold.
• Children's products where the supplier refuses testing and certification.
• Hazardous materials, flammables and pressurized goods outside our competence to handle safely.
• Protected wildlife and species restricted under CITES, including ivory.
• Surveillance and interception devices, signal jammers, and lock-picking or theft tools.
• Any project whose purpose is to evade duties, quotas, trade remedies or a partner-agency requirement.

6. Forced labor and UFLPA

Merchandise made with forced, convict or child labor is prohibited from entry under 19 U.S.C. § 1307, and the Uyghur Forced Labor Prevention Act creates a rebuttable presumption against goods with any input from Xinjiang. We ask manufacturers to identify the origin of sensitive inputs, particularly cotton, polysilicon and tomato derivatives, we document what they answer, and we recommend against suppliers who will not answer at all.

7. Sanctions and denied parties

We comply with the sanctions programs administered by the U.S. Treasury's Office of Foreign Assets Control (OFAC). Suppliers, clients and counterparties are screened against the SDN List, the BIS Denied Persons and Entity Lists and comprehensively sanctioned jurisdictions. We do not work with blocked persons, entities owned fifty percent (50%) or more by them, or transactions involving sanctioned destinations.

8. Anti-corruption and supplier gifts

• We comply with the U.S. Foreign Corrupt Practices Act. Neither VMA nor anyone acting for us may offer or pay anything of value to a government official, inspector or private counterparty to obtain an improper advantage, including facilitation payments.
• We do not accept commissions, rebates or gifts from suppliers. Where one is offered, we decline it and inform the client. This is a compliance rule for us, not only a commercial promise.
• A client instruction to pay a bribe, falsify a document or mislead an inspector ends the engagement immediately.

9. Customs valuation and declarations

We will not assist in undervaluing goods, misdescribing merchandise, splitting shipments to evade duties or thresholds, misstating the country of origin, or arranging transshipment to disguise origin. Where a supplier proposes any of these, we advise against it in writing and, if it continues, we withdraw from the project. Correct classification and valuation cost far less than a penalty notice.

10. Recordkeeping

Supplier verification files, specifications, inspection reports, certificates and the correspondence supporting them are retained for five (5) years, so that you can meet the recordkeeping expectations placed on importers under 19 C.F.R. Part 163 and defend an entry if it is questioned.

11. Right to refuse

We may decline, pause or terminate any engagement, and disclose the matter to the competent authorities, where we believe a project would breach applicable law or this policy. We do so without liability for consequential loss. Fees for work not performed are refunded as described in our Fees, Cancellations & Refunds Policy.

12. Reporting a concern

Report a suspected violation, or an intellectual property claim, to legal@vmaglobaltrade.com. Reports may be made confidentially, and we do not retaliate against anyone who raises a concern in good faith.

Questions about this document

Write to legal@vmaglobaltrade.com or mail us at VMA Global Trade LLC, 1200 Brickell Ave, Suite 1950, Miami, FL 33131, United States. We respond to written requests within thirty (30) days.