On July 17, 2020, the Federal Emergency Management Agency (FEMA) published a request for comments on the letter of attestation process in connection with the export restrictions on certain personal protection equipment (“PPE“).  These restrictions were imposed earlier this year in response to the COVID-19 pandemic.  Our previous blog posts on the FEMA restrictions and their exemptions can be found here and here.  FEMA requires that exporters submit a letter of attestation via a document management system overseen by US Customs and Border Protection (CBP) for exemptions from FEMA’s export restrictions on certain PPE products.  These export restrictions are currently in place until August 10, 2020.  FEMA’s request for comments may potentially be an indication that the US government could be considering an extension of these restrictions beyond the current expiration date.  Exporters that have experienced issues with submission or processing of these letters of attestation are able to submit comments through September 15, 2020. 

Our previous blogs posts on trade restrictions imposed throughout the COVID-19 pandemic can be found here.  Baker McKenzie’s COVID-19 Product Import/Export Review (“COVID-19 PIER“), a multijurisdictional tracker for trade restrictions imposed worldwide, can be found here.

Author: Kerry B. Contini. The author acknowledges the assistance of Ryan Orange in this article.


Ms. Contini focuses her practice on export controls, trade sanctions, and anti-boycott laws. This includes advising US and multinational companies on trade compliance programs, risk assessments, licensing, review of proposed transactions and enforcement matters. Ms. Contini works regularly with companies across a wide range of industries, including the pharmaceutical/medical device, oil and gas, and nuclear sectors.