Export License Best Practices: Medical Items to Russia, Belarus & Occupied Regions of Ukraine

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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.

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Topics: Export Compliance, Russia, Export Consulting, Pharamaceutical

Chemical & Pharmaceutical Tariff Classification

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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.

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Topics: Classification, Pharamaceutical