Medical items being exported from the US to Russia, Belarus, and occupied regions of Ukraine may require an export license. The sanctions set forth under Sections 746.5, 746.6, 746.8, and 746.10 of the Export Administration Regulations (15 CFR Parts 730-774, “EAR”) are designed to include the prohibition of medical item exports that support military involvement in the ongoing conflict in Ukraine. There is a policy of denial for The Ministries of Defense of both the Russian Federation and Belarus. However, license applications for health and safety, medical, and humanitarian items destined for civilian facilities are reviewed and may be approved on a case-by-case basis.
Jim Conrad
Recent Posts
The U.S. Food and Drug Administration (FDA) is responsible for ensuring that all food, drugs, and medical devices imported into the United States meet the country's safety and quality standards. However, there are times when FDA import clearance delays occur, causing frustration for importers. Some of the most common reasons for delay include:
Topics: Import Consulting
Why is it that chemicals and pharmaceutical items are often classified incorrectly? The answer has more to do with the nature of pharmaceutical trade than the complexity of the tariff (though it is complex). In an industry with its fair share of non-commercial product movements for testing, diagnosis, analysis, and new product development, that ‘newness’ and the speed at which product moves can make compliance determination challenging. However, meeting reasonable care standards makes attention to and investment in an accurate classification process critical. Here are some tips on how to get it right.
Topics: HS Classification
The Court of International Trade has ordered that the tariff actions imposed by the Office of the United States Trade Representative, as amended on remand by Further Explanation of the Final List 3 and Final List 4 Modifications Pursuant to Court Remand Order, ECF No. 467, are sustained.
In a nutshell, while the Court ordered the government to correct the record - ECF 466, Sec. 301 Final Lists 3 & Final 4a are valid and remain in place.
Topics: Asia, Import Consulting, North America
It has been two years since the implementation of the United States – Mexico – Canada Free Trade Agreement. For those of you reading this outside of the US, the agreement is referred to in Canada as the Canada – United States – Mexico Agreement (CUSMA); and in Mexico, this agreement is referred to as Tratado entre México, Estados Unidos y Canadá (T-MEC). All three names refer to the same trade agreement.
Topics: Free Trade Agreements, North America