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.

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


Ms. Lis has extensive experience advising companies on US laws relating to exports and reexports of commercial goods and technology, defense trade controls and trade sanctions — including licensing, regulatory interpretations, compliance programs and enforcement matters. She also has advised clients on national security reviews of foreign investment administered by the Committee on Foreign Investment in the United States (CFIUS), including CFIUS-related due diligence, risk assessment, and representation before the CFIUS agencies.


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.