Exports of Medicine and Medical Supplies to Iran
OFAC has authorized the exportation and re-exportation of certain qualified medicine and medical supplies to Iran pursuant to a general license.
See Section 560.530(a)(3)(i).
This general license specifically authorizes U.S. persons and other covered persons to export or re-export such goods to any individual or entity in Iran, or to persons in third countries purchasing specifically for resale to any such Iranian individual or entity.
It also authorizes the conduct of related transactions including, but not limited to:
- Making of shipping and cargo inspection arrangements,
- Obtaining of insurance,
- Arrangement of financing and payment,
- Shipping of the goods,
- Receipt of payment, and
- Entry into contracts (including executory contracts).
The specific list of medical supplies subject to this general authorization is listed on OFAC’s website. Please
click here for a pdf copy of the list.
The list includes many basic medical supplies, including syringes, forceps, lancets, IV sets, condoms, and surgical kits, just to name a few.
Exporters should consult the list prior to exporting such items to Iran because the contents of the list may change as U.S. foreign policy and national security objectives evolve.
The list also indicates that components, accessories, and optional equipment that are designed for use with EAR99-classified medical devices can also be exported to Iran so long as the primary medical device appears on the list. If the medical device does not appear on the list, specific license authorization must be obtained from OFAC prior to engaging in the transaction.
OFAC has also determined medicine can be exported to Iran. Medicine is an item that falls within the definition of the term “drug” in section 201 of the Federal Food, Drug, and Cosmetic Act and that, in the case of an item subject to the EAR, is designated as EAR99 or, in the case of an item not subject to the EAR, that would be designated as EAR99, if it were located in the United States.
Excluded Medicine
However, the following medicine are
excluded from the general license:
- Non-NSAID analgesics,
- Cholinergics,
- Anticholinergics,
- Opioids,
- Narcotics,
- Benzodiazepines, and
- Bioactive peptides.
Anyone seeking to export such excluded medicine to Iran must first obtain a specific license from OFAC.
Iran-Related TSRA Food and Medicine Exports
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