Importation of Covid-19 response medical products

In light of the Covid-19 situation, many traders now find themselves attempting to import or export pharmaceuticals, medical support products and medical devices across borders. However, since many of these traders have never dealt with such items before, oftentimes they get stuck on licensing issues, HS classification issues or temporary provisions put in place by countries to restrict movement of these products.

Here are a few things traders dealing with medical supplies should take note:

1. Medical devices & pharmaceuticals require pre-approval in most countries. Medical devices can vary from tongue depressors to surgical implants. Each medical device will typically be assigned a risk class by the Health Authority of the importing country. The higher the risk class, the more onerous the licensing requirements can be expected to be. If you intend to import any product even vaguely related to medical use or use in a hospital, clinic or laboratory – it is best to check with the local health authority if the product you intend to import falls under the definition of a medical device or not in that country. This includes PPE products such as masks, gloves, gowns and protective glasses. In order to import medical devices in the higher risk classes, you can expect to be required to produce documents such as certificates of conformance, certificates of analysis, Free Sale certificates, US FDA certificates (if sourced from US) and/or item catalogues or brochures. Similarly, the import of pharmaceuticals into countries will also require extensive documentation to be provided to authorities. While the approval for both medical devices and pharmaceutical products and take more than a month in many cases, some countries have implemented fast track options for getting medical supplies approved in order to support the fight against Covid-19. Nonetheless, it is best to ensure you have the licenses to import the product before you instruct your supplier to ship. Given the reduced manpower in most ports around the world, you don’t want to find yourself dealing with an abandoned shipment in the port because you don’t have a license necessary for import. This is an important consideration even if you are buying on DDP Incoterms, as you may be forced to act as importer of record for certain types of products in some countries.
2. Some countries have banned exports of specific medicines, vaccines, PPEs and other products. Ensure that there are no temporary restrictive measures in your source country prohibiting the export of the goods you have ordered. You can find that information easily here.
3. Duty free imports of certain medical products maybe possible. Some countries now allow duty free imports of specific medical devices and/or donations to fight Covid-19. The importer typically has to make an application for duty exemption to Customs for such imports. Check with the local Customs authorities if such measures exist and ensure you do not end up paying more duty than you have to.
4. Import and distribution licenses may vary! Be wary of local laws concerning the distribution of medical supplies and products. You may meet the requirements to import a medical product but not the requirements to distribute it locally. Ensure you clarify these requirements with local health authorities before you find yourself in your warehouse looking at 10 containers of testing kids that you are not allowed to sell.
5. Disinfectants are usually dangerous goods. Most sanitizers have some form of alcohol base as the main active ingredient. These are also usually highly flammable materials. Ensure you have them correctly packaged for cross border movement.
6. Refer to WCO’s HS codes for commonly traded medical products. In order to facilitate countries that need to quickly implement import/export controls and policies regarding the cross border movement of medical products, the World Customs Organization has released guidance on HS classification of commonly traded medical supplies and products like ventilators, testing reagents and masks. Refer to this document but always double check the HS code with a trained professional to be sure.

Traders who find themselves involved in moving medical supplies in this crucial time should exercise due diligence to ensure that they are able to ship products seamlessly across borders to the people that need them. Every logistician involved in such activities has a very significant part to play in the fight against Covid-19 that is expected to last over the next several months.