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Impact of sanctions against Russia on importers of iron and steel products

From 30 September 2023, importers of iron and steel products into the EU are newly obliged to prove that they did not use iron or steel of Russian origin in their production. The measure is part of a package of sanctions against Russia that had been postponed to give the importers more time to prepare. A necessary condition for the purchase and import of iron and steel products from non-EU countries will be to prove the origin of the raw materials used in processing.

The measure applies to products included in Chapters 72 and 73 of the Harmonised Commodity Description and Coding System and the Combined Nomenclature, except for Subchapters 7201-7205. The ban on the purchase and import of products originating in Russia has already been in place but will now be extended to iron and steel products of Russian origin but processed outside Russia. Declarants should therefore check whether they import products that fall under those chapters or chapters regulating exemptions.

How to prove the origin of raw materials?

To prove the origin of raw materials, the European Commission recommends completing a mill test certificate (sometimes also a material test report), which importers should present to customs when crossing the EU border. Such a certificate shows where the product was finally processed and what the origin of its individual components is. The importer is responsible for the accuracy of the information in the mill test certificate (MTC) and the customs authority shall have the power to request additional information or evidence.

The customs administration also considers other documents permissible to prove that no raw materials with any relation to Russia were used in production: such as one-off or long-term supplier declarations or commercial, production and customs documents proving the non-Russian origin of iron and steel. The procedure to prove origin for re-imports and other non-standard consignments has yet to be clarified.