Are you importing or planning to import Personal Protective Equipment (PPE)? PPE, once a low-value item, is now the fastest growing commodity by volume and by value in Europe and North America.

Did you know that James J Boyle & Co has more than 40 years of experience handling Customs and FDA clearances of food and medical products? At James J Boyle & Co we have your back when it comes to international freight forwarding and U.S. import clearance of PPE! Please contact us for more information and find out why our customers are so satisfied with our service!

Tips on Importing Face Masks or other PPE as Trouble-Free as Possible

  • Whether masks are considered medical devices or not, is based on intended use, regardless of how it is sold.
  • Labeling is a key characteristic when determining if FDA clearance is required.
  • Labeling of Non-Surgical Face Masks that do not require FDA entry:
    • Masks must be labeled accurately to describe the product as a face mask and include a list of the body-contacting materials (cannot include any drugs or biologics).
    • Masks intended for personal, non-medical use, must NOT be labeled or marketed as “surgical masks” or that it provides liquid barrier protection.
    • The labeling must include recommendations against use in a clinical setting where the infection risk level through inhalation exposure is high.
    • Labeling cannot state or imply that the product is intended for antimicrobial or antiviral protection or for use in infection prevention.
    • The product cannot be labeled as a respiratory protective device or for use for particulate filtration or labeled for use in high risk aerosol generating procedures.
  • Non-FDA-regulated PPE such as face masks that are for General Purpose or Industrial Use do not require FDA entry and may be disclaimed.
  • Surgical (medical) Masks: Depending on device classification, premarket notification may be required.
  • FDA Registration: All manufacturers of medical devices must register with the FDA. See Device Advice and How to Study and Market Your Device links.
  • EUA: To battle the COVID outbreak, FDA has authorized an Emergency Use Authorization for certain PPE. For information related to this authorization please review the NIOSH-Approved Disposable Filtering Facepiece Respirators for Use in Healthcare Settings During Response to the COVID-19 Public Health Emergency.
  • N95 masks: FDA guidance states that such masks may be imported with lower restrictions if going to medical professional organizations, and can be disclaimed if the masks are for non-medical uses.
  • KN95 masks (the Chinese equivalent of N95 masks): can also be brought in with lowered restrictions but FDA is still very strict about the types of masks eligible for these modified requirements.
  • Hand Sanitizers are over-the-counter drugs regulated by FDA, are listed on the National Drug Code (NDC) Directory, and must include a “Drug Facts” label.

Medical PPE Checklist

If the PPE items you intend to import ARE intended for medical use, FDA must be claimed and the following information is generally required:

  • Device Listing Number
  • Manufacturer Registration Number
  • Exporter Registration Number
  • 510(k) Premarket Number

Emergency Use Authorization (EUA) Approved PPE

  • If the item is listed as “approved for EUA, the above information becomes optional by using an “Intended Use Code”.
  • Providing the information to FDA at time of entry is still encouraged if the importer has it.
  • See list of specific EAU-approved models of diagnostic tests and masks/respirators, which include National Institute for Occupational Safety and Health (NIOSH)-approved and non-approved masks.

Non-EUA Items

  • Items not listed as approved for EUA can still be imported with reduced restrictions using a different intended use code.
  • The intended use code flags the item as being subject to reduced restrictions due to a published enforcement discretion policy. The FDA checklist information above is also waived for this category.
  • This category includes items such as non-invasive remote monitoring devices, ventilators, and other accessories/respiratory devices.
  • Although the U.S. reduced enforcement, China has increased enforcement. Therefore it is important that your shipper confirm in advance that it has all necessary approvals and licenses from the Chinese government even if the U.S. does not need this information at time of entry.

ACE Entry Requirements for Non-EUA KN95, KN100, KP100 and KP95

  • Program Code: DEV
  • Processing Code: NED
  • Intended Use Code: 940.000 if the product is listed on the CDC website
  • Intended Use Code: 081.001 if not listed on the CDC website
  • Product Code: 80N-ZJ

Also see Customs & Border Protection’s Information for Filing Personal Protective Equipment and Medical Devices During COVID-19 and CBP’s PPE Importing Guidance page.

For additional detailed information concerning various U.S. government agencies’ updates related to COVID-19, we have gathered and provided their webpage links, which are grouped by government agency sections.

If you have any questions, please do not hesitate to contact the experts at JJB!

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SPECIAL PROJECTS

SPECIAL PROJECTS

SPECIAL PROJECTS

Have a special shipment? We use the latest technology to research and create the best custom packages to get the project done.

We are at our best when confronted with a logistical challenge, one-time project or other special need. With more than 50 years’ experience, access to the latest technology and world-class Customs Brokerage and freight forwarding expertise, we can help design customized solutions that meet your needs.

For more information about how we can help you, please contact us at our office location most convenient to you.

CUSTOMS BROKERAGE

CUSTOMS BROKERAGE

CUSTOMS BROKERAGE

You have someone on your side that understands the rules and regulations that your cargo will need to meet in order to ensure a streamlined shipping process and expedited Customs clearance.

Our relationships with government agencies and gatekeepers helps to minimize delays that might be brought on by new legislation, updated requirements, or any other potential road blocks. We continuously stay up to date on industry news and trends. Our goal is to cover every logistical base making it possible for full Customs release prior to cargo arrival into port.

From raw materials to processed goods, we ensure that your cargo reaches its destination in the most cost-efficient manner.

We can assist you by pre-clearing your cargo, providing last-mile final delivery services to the ultimate U.S. destination, or warehousing services as your needs dictate.

INTERNATIONAL LOGISTICS

INTERNATIONAL LOGISTICS

INTERNATIONAL LOGISTICS

We will handle all of the planning and booking of your inbound and outbound cargo while giving you real-time status updates in the most efficient and transparent way possible.

Our team provides the latest freight rates, whether ocean or air, to ensure the most competitive bids are secured for you. We will also manage the documentation making it a smooth process from port to port. We can provide a full range of booking services, freight cost analysis, and coordination of your jobs requiring multi-modal transportation when you choose us for your logistics needs.

EXPORT

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With ever growing export regulations and special rules or sanctions on specific countries, you need an expert that can properly screen cargo to ensure it meets TSA standards and file the necessary data via AES (Automated Export System).

Our expert staff will export your cargo via ocean or air expeditiously and with great care.

CONSULTING

CONSULTING

CONSULTING

Decades of experience as a successful freight forwarder and U.S. Customs broker puts us in the unique position to advise and consult with you as you seek to enter or expand your presence in global trade.

Your regulatory and logistical needs are as unique as your business! Whether you need tariff classification advice, a binding ruling, drawback services, or assistance with an internal audit, we take pride in delivering the kind of custom-tailored services that are difficult to find in larger companies. Take the first step towards success in the world of international freight forwarding and Customs brokerage by contacting our consulting division today.

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