PPE Supply Chain Video Series - Volume 2

Hi, My name is Ben Bidwell and I'm the Director of North America Customs and Compliance here at C.H. Robinson.

These arecertainly some unprecedented times that we're living in today. I hope that you and your families are all staying safe. PPE or personal protective equipment has become an essential and everyday use for all of us. As more and more companies are importing PPE, I wanted to share some best practices and highlight some resources that are available.

When importing PPE into the U.S. it is important to understand what requirements there are from a CBP and FDA perspective as well as possible other government agencies, depending on the commodity that you're importing. In making these determinations, one of the main questions to answer is whether the goods are for medical or general use.

However, it's not only the intended use of the product that you need to pay attention to. If the goods air for general use, the labeling, packaging, and marketing of the product cannot make any medical claims.

The FDA has also utilized certain procedures to accommodate the influx and need for PPE. Understanding FDA's emergency use authorizations and enforcement policies are vital. Depending on the PPE commodity you are importing, there could be multiple CBP and FDA requirements to navigate.

Things change rapidly in this environment. For example, FDA recently revised their requirements for importing KN95 masks into the U. S. It is important that you stay up to date with the changing requirements and utilize the resources available.

The World Customs Organisation, CBP, and FDA have all done a great job in providing valuable resource is and guidance documents.

Importing PPE into Canada certainly has some similarities of importing into the U. S. However, it's not the same. While intended use, labeling, packaging and advertising could be used to determine medical vs general use in Canada. It is ultimately at the discretion of Canadian inspectors. The majority of PPE being imported into Canada is considered a Class One medical device, and carries import requirements with Health Canada.

Certain PPE are considered Class 2 medical devices and carry additional requirements. Similar to the U. S., Health Canada and the CBSA have resource is available to the trade that should be utilized.

Lastly, the Department of Finance in Canada instituted duty reduction measures for PPE, effective May 5th of this year [2020]. This covers a wide variety of COVID-19 related imports. One of the most critical takeaways I would like to leave you with, whether you're important PPE into the United States or Canada, is to make certain that you understand the requirements of what you're importing prior to the goods moving from origin. In doing so, you will significantly reduce your risk of costly delays and potential product refusal at destination.

Wow, that was certainly a lot of information and C.H. Robinson is here to help. Please reach out to your C.H. Robinson contact with any questions. Thank you so much for watching this quick video and look for future PPE related videos from us soon. Have a great day and stay safe.

Customs best practices for personal protection equipment (PPE)

Whether you’re looking to import PPE for the first time or as part of your normal procurement process, C.H. Robinson’s experts can help you build a more resilient supply chain when navigating customs for PPE.

Importing PPE into the U.S. and Canada

Watch Ben Bidwell, director of North America customs and compliance, in this quick video as he discusses the best practices and resources you’ll need to successfully navigate the many regulations and agencies involved in bringing PPE into the United States or Canada without delay. He’ll explain why it’s important to know:

  • If your PPE is meant for medical or general use
  • The differences between importing PPE into the United States and Canada
  • Where to find the latest PPE requirements