TradeLane

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.

Customs Procedures become increasingly attractive to companies with higher exposure to duties as their business grows through expansion or as they try to enter new markets. Customs Procedures can greatly reduce the duty burden on a company, ensuring that duties are paid when goods are sold as opposed to when they are brought into the European Union or simply not paid because a destination outside the Union has been found for the goods.

The introduction of the Authorized Economic Operator (AEO) program in the European Union in 2008 brought exponential growth in this supply chain security program that has slowed as it has matured and the pool of non-AEO traders has declined. That growth curve is documented in this EU AEO valid Authorizations per year chart.

Acquiring an authorization, or as some would say, a certification proves that you have mastered a particular ability. You have spent time studying, understanding, and developing a skill set and are now authorized to apply that skill. You work towards these certifications throughout your life -- be it your Boy/Girl Scout badges, school diplomas, or your driving license.

Understanding Dual-Use regulation, or regulation controlling the export of commodities with a civilian or military end-use, can be complicated. The development of these rules and regulations continues. Regulators are trying to keep up with the technical developments in the market, geopolitical developments globally, and their own economic interests. European regulators meet with traders within the European Union periodically at the European Union (EU) Export Control Forum to discuss the topic at hand and share best practices and developments.