Import entries of iron and steel products

With this article we inform you about the import of certain iron and steel products which we are carrying out on your behalf in relation to the sanctions in force against Russia.

Regulation (EU) 2023/1214 of June 23, 2023, extended the existing sanctions on Russia (Regulation (EU) 2014/833). Article 3g (octies) of the regulation introduces an additional provision to tighten sanctions on certain iron and steel products. This addition will enter into force on September 30, 2023.

The mentioned regulation refers to all iron and steel products that incorporate iron and steel products originating in Russia listed in Annex XVII (Annex), subject to the exceptions set out in Article 3g (octies).

We would like to inform that as of September 30, 2023, additional proofs of origin (besides any certificate of origin) must be presented with each customs entry for the affected goods.

The European Union has published a Frequently Asked Questions/FAQ document on this subject. For a complete overview of the new regulations, we refer to the content of the mentioned regulations and to the FAQ. In relation to the FAQ, the "Mill Test Certificate" (MTC) is a possible suitable proof of origin. However, the statements of the customs authorities are still cautious which proofs are considered conclusive.

According to the FAQ (page 12 under point B), an MTC must contain at least the following information:

The following documents may be considered as sufficient evidence of the country of origin of the iron or steel used as inputs:

a) In the case of semifinished products:
The mill test certificate (MTC) (there is no concrete standardized format):
- establishing the name of the facility where the production is taking place, the name of the country corresponding to the heat number (country of the ladle of melting) together with the classification at subheading level (six-digit code) of the product.

b) In the case of finished products:
The mill test certificate (MTC) or mill test certificates (MTCss) – if all relevant information cannot be summarized in one single MTC or the MTC accompanied with other documents:
- establishing the name of the country and the name of the facility corresponding to the heat number (country of the ladle of melting) together with the classification at subheading level (six-digit code), and
- the name of the country and the name of the facility where the following processing operations are carried out, as relevant:

• Hot-rolling
• Cold-rolling
• Hot-dipped metallic coating
• Electrolytic metal coating
• Organic coating
• Welding
• Piercing/extruding
• Drawing/Pilgering
• ERW/SAW/HFI/Laser welding

The importer is responsible for the information provided in the MTC or MTCs and submitted to the customs authorities of the Member State of import as evidence of the country of origin of the iron and steel inputs used.

Multiple MTCs may be submitted for finished products if there is not enough space to process the required information on one MTC. All information must be understandable and clearly appear on the MTCs. If the (customs) authorities have reasonable doubts about the accuracy or completeness of the documentation presented, additional documentation/information may be requested.

We understand that this information may raise questions on your behalf. For this reason, we have attached the European Union's FAQ document on sanctions against Russia via the following link: https://finance.ec.europa.eu/system/files/2023-10/faqs-sanctions-russia-consolidated_en.pdf