On July 1, 2021, the Federal Emergency Management Agency (“FEMA”) announced that the temporary final rule that placed export restrictions on certain medical supplies and personal protection equipment products (“PPE Products”) has expired.  There are now no current export restrictions on these items.  The temporary final rule was first published in April 2020 to allocate scarce medical supplies and PPE products for domestic use in response to the COVID-19 pandemic.  Exemptions from export restrictions were published shortly after.  The temporary final rule was modified and extended in August 2020 and then again in December 2020.  Additional exemptions from the temporary final rule were announced in June 2021, but the temporary final rule was not extended and expired at the end of the month. 

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.

The authors acknowledge the assistance of Ryan Orange in this blog post.


Mr. McMillan's practice involves compliance counseling; compliance programs; licensing; compliance reviews; internal investigations; voluntary disclosures; administrative enforcement actions; criminal investigations; customs inquiries, audits, detentions, and seizures; and trade-compliance due diligence and post-acquisition integration in mergers and acquisitions. His practice includes matters that implicate the US International Traffic in Arms Regulations (ITAR), US Export Administration Regulations (EAR), US National Industrial Security Program (NISP), the US Committee on Foreign Investment in the United States (CFIUS), and equivalent non-US laws. Mr. McMillan regularly advises on and represents clients in matters involving technology, including its control, protection, accidental disclosure, diversion, or unauthorized collection. Mr. McMillan has extensive experience working with companies in the aerospace and defense industry, as well as companies in the Middle East and other parts of Asia.


Meg's practice involves assisting multinational companies with export compliance related matters, specifically trade sanctions and export control classifications. Additionally, she assists companies with respect to customs laws, anti-boycott laws and other trade regulation issues in the US and abroad. She also helps obtain authorizations from the US government for activities subject to sanctions regulations and US export control regulations, including the Export Administration Regulations and the International Traffic in Arms Regulations. Meg's practice extends to assistance in internal compliance reviews as well as enforcement actions and disclosures necessitated by US government action.