COVID-19: What Customs impact? (2/2)

April 08, 2020
by Ghislain de Pazzis

Among the numerous measures or communications in the context of the action against the Covid-19 epidemic, we provide an overview, in two parts, of those relating to Customs rules. 

Part 2: Specific support measures in response to the epidemic. 


Additional Customs simplification to facilitate and accelerate the manufacture of hydro-alcoholic gels

Customs Authorities have implemented a simplified procedure to enable pharmacists to have alcohol delivered in order to make hydro-alcohol gel to combat Covid-19 and recalls the conditions to be met in order to benefit from exemption from excise duties (delivery of denatured alcohol – Art. 302 D bis I b of FTC).
This simplified procedure is for retail pharmacists or pharmacists working at an in-house pharmacy who wish to prepare hydro-alcoholic solutions intended for human hygiene in application of the decree of 6 March 2020 adopting various measures relating to the fight against the spread of the virus Covid-19. Cf. Customs Authorities Notice of 17 March 2020.

Moreover, the Minister of Public Actions and Accounts has, exceptionally, authorized hydro-alcoholic gel manufacturers to replace denatured alcohol with undenatured alcohol in the manufacturing formula. This exceptional authorization will be granted to HAG manufacturers by the customs authorities so that they can continue to benefit from the exemption from duties. Interested operators should contact their Economic Action Division (Pôle d’Action Economique, “PAE”)  to obtain further information.


Please note: Exportations of personal protective equipment subject to authorisation

Commission Implementing Regulation (EU) 2020/426 amending Implementing Regulation (EU) 2020/402 makes the exportation of certain personal protection equipment subject to the production of an export authorisation in the context of the coronavirus epidemic and an information note from the European Commission assists in the implementation of these provisions. This is to control the flow of equipment ensuring the protection of persons (masks, visors, glasses, gloves, etc.). The list of CN codes is provided.
These provisions shall enter into force on 21 March 2020 and should be applied until 26 April 2020 (unless renewed).
Exportations to Norway, Iceland, Liechtenstein, Switzerland, as well as to the overseas countries and territories listed in Annex II of the EC Treaty and Faroe Islands, Andorra, San Marino and the Vatican City are not subject to this export authorisation.
The exportation of certain quantities of specific products may be authorized to ensure the supply of emergency operations of humanitarian organisation in third countries.
In France, the Service for dual-purpose goods is responsible for handling these requests and must decide within a period not exceeding 5 business days as from the date when all of the information required has been provided.
Such requests should be sent in dematerialized form, accompanied by a letter explaining the context, to the following address:
More detailed instructions are expected.  


Customs classification of hydro-alcoholic gels

The Customs classification of hydro-alcoholic gels depends on their composition, and notably whether they are based on quaternary ammonium salts, halogen compounds or other products.

The decree of 13 March 2020 specifies the 3 formulas of hydro-alcoholic gels used as disinfectant biocides for personal hygiene, all classified under heading 38 08 94 90 90 if they are not packed with aerosols techniques containing HFC for which the GWP is greater than or equal to 150.


Customs classification of masks French

Customs has also specified the Customs classification applicable to different types of protection or respiratory masks used in the fight against the epidemic.

  • Textile masks (surgical masks IR or IIR and masks of type FFP1/FFP2/FFP3, N95...) classified under heading 6307 90 which covers “other made up textile articles of woven fabric”, and not heading 9018 which covers “ Instruments and appliances used in medical, surgical, dental or veterinary sciences, including scintigraphic apparatus, other electro-medical apparatus and sight-testing instruments”.
  • Classification of respiratory mask for medical apparatus: 9019 20 00 00 “Ozone therapy, oxygen therapy, aerosol therapy, artificial respiration or other therapeutic respiration apparatus”.
  • Classification of gas masks: Gas masks provided with mechanical parts and removable filters, which consists of, in most cases, a mask with a vision device, a baseplate with inhalation and expiration valve, an orifice on which adapts either the filtering cartridge, or a flexible tube connected to a filtering system placed on the back or on the chest, excluding masks for civil aircraft, classified under the heading 9020 00 00 80.
  • Classification of parts of gas masks: Parts of gas masks (excluding gas masks for use in certain types of aircraft) classified under the heading 9020 00 00 80.


Exempt importations and deliveries of goods necessary to provide assistance to populations

To facilitate the supply of materials and equipment needed both to combat the epidemic and to ensure personal care and protection, the following are exempt from dock dues and from regional dock dues: 

  • hydro-alcoholic gels and products intended as components thereof;
  • medical equipment such as masks, gloves and breathing apparatuses.

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