On June 14, 2021, the Federal Emergency Management Agency (FEMA) announced new exemptions from a temporary final rule placing export restrictions on certain types of medical supplies and personal protection equipment products (“PPE Products“) used in response to the COVID-19 global health pandemic.  The new exemptions include industrial N95 respirators, PPE surgical masks, and specific syringes and needles.  The temporary final rule is set to expire on June 30, 2021. 

FEMA first imposed export restrictions on certain PPE Products on April 7, 2020, to reserve supplies for domestic use to combat the COVID-19 pandemic, as described in our blog post here.  Exemptions from the export restrictions were issued in April and the original temporary final rule was modified and extended in August 2020.  In December 2020, FEMA expanded the list of covered PPE Products to include certain syringes and hypodermic needles, in light of the high rate of influenza vaccine administration and the rollout of the COVID-19 vaccines, as described in our blog post here

All 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.

Authors: Sylwia A. Lis and Meghan Hamilton.

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Sylwia Lis is a member of the Firm's International Trade Practice Group.

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Meghan (Meg) Hamilton is a member of the International Commercial Practice Group and the International Trade Compliance Sub-Practice Group in Baker McKenzie, Chicago, where she has been an associate since 2015. Meg regularly assists multinational companies on sanctions, customs and export control compliance as well as other international trade matters, including commercial agreements and anti-boycott regulations. She is active in civic activities throughout Chicago, serving on the Young Professional Board of the Center for Disability and Elder Law as well as the Auxiliary Board of the Chicago Legal Clinic.