Dumpers have proven themselves to be a highly imaginative lot. Here are a few of the tricks they have devised to circumvent regulatory agencies at home and suspicious importers abroad.
THE NAME CHANGE: When a product is withdrawn from the American market, receiving a lot of bad publicity in the process, the astute dumper simply changes its name.
THE LAST MINUTE PULLOUT: When it looks as if a chemical being tested by the Environmental Protection Agency won’t pass, the manufacturer will withdraw the application for registration and then label the chemical “for export only.” That way, the manufacturer doesn’t have to notify the importing country that the chemical is banned in the U.S.
DUMP THE WHOLE FACTORY: Many companies, particularly pesticide manufacturers, will simply close down their American plants and begin manufacturing a hazardous product in a country close to a good market.
THE FORMULA CHANGE: A favorite with drug and pesticide companies. Changing a formula slightly by adding or subtracting an inert ingredient prevents detection by spectrometers and other scanning devices keyed to certain molecular structures.
THE SKIP: Brazil — a prime drug market with its large population and virulent tropical diseases — has a law that says no one may import a drug that is not approved for use in the country of origin. A real challenge for the wily dumper. How does he do it?
Guatemala has no such law; in fact, Guatemala spends very little each year regulating drugs. So, the drug is first shipped to Guatemala, which becomes the export nation.
THE INGREDIENT DUMP: Your product winds up being banned. Don’t dump it. Some wise-ass reporter from Mother Jones will find a bill of lading and expose you. Export the ingredients separately — perhaps via different routes — to a small recombining facility or assembly plant you have set up where you’re dumping it, or in a country along the way. Reassemble them and dump the product.