The Review of Sanction Measures of Unfriendly Countries Related to Exporting and Re-Exporting of Medical Items to Russia

The constantly increasing measures of sanctions impact contribute to advancing development of political conflict of Russia with unfriendly countries, that results in increasing economic pressure on sectors of the Russian consumer market that are the most import-dependent ones. Currently, the European Union, the United States, Japan and other states that received status of unfriendly ones, are actively applying secondary sanctions originally developed as tool to curb schemes of circumventing existing bans against Russia, of which legalization of parallel imports, introduced in 2022, was among the most effective ones. By their content, secondary sanctions imply possibility of imposing prohibitive measures on foreign counter-agents from countries that are friendly for Russia, that cause additional difficulties with registration, making payments and increased delivery time. Of course, all the circumstances mentioned above could not help but affect export and re-export of medical devices to Russia. The detailed analysis of content of imposed sanctions measures established that currently there are no direct bans on export and re-export of medical equipment, as well as components and consumables, parts and accessories. The only exception are medical devices classified as dual-use goods and fairly large number of complex technological equipment, including its components, that fell under measures of strengthening export control imposed by the United States. Despite the fact that there are no formal sanctions against medical equipment and articles, in practice they are actively used, and given absence of unified methodology, issue of their implementation becomes even more ambiguous and problematic that makes the topic under consideration relevant. The article examines in detail main content of the prohibitive and restrictive measures taken within the framework of the sanctions impact from unfriendly states in relation to export and re-export of specialized medical equipment and components. Also are considered the listing of goods classified as of dual-use in terms of medical devices. The detailed list of medical products for which the US requirement to issue an export license for their export applies is presented. The practical recommendations are formulated to address main problematic issues.