export of certain products - Regulation (EU) 2020/402 - latest update 14/04/2020

update 14/04/2020

The EU Commission DG TRADE published a news article titled : European Commission narrows down expert authorisation requirements to protective masks only and extends geographical and humanitarion exemptions.

In the article the Commission announces the start of consultations with the member states on Regulation 2020/402, which ends automatically on the 26th of April if there is no ammendment or new Regulation. The proposal of the Commission is to limit the export limitations to masks only. 

see for the news article : https://trade.ec.europa.eu/doclib/press/index.cfm?id=2132


update 10/04/2020

With the meeting of the Trade Council of the 16th of April in view, 10 trade associations sent a joint letter to the Council expressing concerns about the current trade limitations. The associations are : Business Europea, EFPIA, CEFIC, Euratex, COCIR, Medicines for Europe, EuropaBio, AESGP, MedTech Europe, EDANA and of course also ESF. The letter can be read here.


update 03/04/2020

ESF sent a letter to the Commissioners and the Council presidency expressing our concerns about the export limitations and national measures limiting the trade of certain types of PPE. Also concerns related to the Recommendation 2020/403 on conformity assessment and the appeals to produce 'artisanal' masks are included in our letter. The letter can be read here.


update 02/04/2020

on the webpage of DG TRADE (https://trade.ec.europa.eu/doclib/press/index.cfm?id=2123) there is now also a FAQ added to the documents :


update 26/03/2020

As we receive regular questions about which types of products are included in these export limitations as well as information about PPE being blocked that have no relation at all with protection against the corona virus (e.g. hearing protection), we have updated our proposals for guidance that were shared with the EU Commission on the 20th of March. 

To further clarify, we included a table with some pictures and also with products that, in our view, are not to be included in the list of PPE that are covered by this Regulation on the export of PPE.

This document is a proposal from ESF and is not approved or endorsed by authorities. We believe it can serve as a guide to facilitate the work of all concerned and hope that the EU Commission will issue a similar official document.

download :

ESF Proposal for guidance on annex I of Commission implementing Regulation (EU) 2020/402 - version 20200326

annex to the Proposal


published 24/03/2020 

The EU Commission published a Commission Implementing Regulation making the exportation of certain products subject to the production of an export authorisation.

The Regulation, as well as some guidance documents, including a list of competent authorities is available on the following webpage of DG TRADE : https://trade.ec.europa.eu/doclib/press/index.cfm?id=2123

Available documents on this page include (on the 24th of March) :

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Disclamer ESF

The information contained in this communication (letter, e-mail, on the ESF website or in documents available for download on the ESF website or as attachment to letter or e-mail, etc..) is intended for guidance only and whilst the information is provided in utmost good faith and has been based on the best information currently available, is to be relied upon at the users own risk.ESF will not accept any direct or indirect liability deriving from it. No representations or warranties are made with regards to its completeness or accuracy and no liability will be accepted for damages of any nature whatsoever resulting from the use of or reliance on the information. The guidance is based on available legislation and information and the interpretation of that legislation/information by ESF. Each company based on its own decision-making process may decide to use the guidance in full, partially or not, as it suits its needs but no liability shall be attributable to ESF.


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