Michigan-based Delphi Corporation, maker of auto parts and systems, agreed to a $50,000 suspended fine in connection of three exports of triethanolamine to the PRC and to South Africa. The fine will be suspended for a year provided that Delphi commits no further violations and will be waived thereafter. The fine was the result of a voluntary disclosure by Delphi. The charging documents provide no information as to the quantity or value of the exported triethanolamine, so it’s difficult to put the fine in context.

Triethanolamine is a chemical with diverse uses. It is used as an emulsification agent in shampoos, soaps, shaving cream and various cosmetics. It’s also used in metal cleaning and rust removal, and in lubricating and metalworking fluids. (Think of that the next time you wash you hair or use shaving cream!) The automobile industry uses triethanolamine in machining and grinding fluids. It’s also a mustard gas precursor. Because of the ubiquity of triethanolamine, it’s not surprising that it has been the subject of a number of enforcement actions. We’ve reported on enforcement actions relating to triethanolamine exports previously here and here.

It’s not clear why Delphi was exporting triethanolamine, other than to be used by one of its subsidiaries or OEM manufacturers abroad. Delphi does have several locations in China, although it’s not hard to find sellers of triethanolamine in China, such as this one.

Once again, BIS’s charging documents demonstrate that the agency lacks some familiarity with the item that it is regulating, as was the case, recently, with 6-2-4-2 titanium. Although the charging letter correctly spells the name of the exported item, both the Order and the Settlement Agreement state that Delphi exported “triethanolmine,” which, frankly, should have just looked wrong to anyone who knows anything about chemistry and knows why triethanolamine might be regulated as a dual-use item. Again, I’m not simply complaining about a random typo in the charging documents. Certainly, one can find typos here particularly given our, er, leisurely production schedule. But it’s not too much to ask that the charging documents correctly spell the name of the exported item.

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