The European Union sees a risk that COVID-19 vaccines that are produced in the European Union (“EU”) will be exported from the EU. In an effort to ensure that all citizens from the EU have timely access to COVID-19 vaccines, the European Commission put in place a measure requiring that COVID-19 vaccines-related exports are subject to an authorisation by Member States. On 29 January 2021 the “Commission Implementing Regulation (EU) 2021/111 making the exportation of certain products subject to the production of an export authorisation” (“Implementation Act”) was published. The Implementing Act was adopted by means of a special expedited procedure and entered into force on 30 January 2021. This export restriction only applies to exports from companies with whom the EU has concluded Advance Purchased Agreements. The export restriction remains in force until 31 March 2021.