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Good to know Ban on imports of iron and steel products made of Russian raw materials

Ban on imports of iron and steel products made of Russian raw materials

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by ​Alicja Szyrner

19 October 2023


The European Union has again extended the economic sanctions imposed on Russia. Import of iron and steel products made of Russian raw materials has been prohibited since 30 September 2023. Therefore, importers are now obliged to have documents showing the origin of the iron and steel inputs.
 
The European Commission has published guidelines indicating that the country of origin of iron and steel inputs may be sufficiently evidenced using:
 
  • in the case of semi-finished products: the mill test certificate (MTC) issued by the producer and establishing the country of production, the name of the facility where the production is taking place corresponding to the heat number (country of the ladle of melting) together with the classification at subheading level of the product,
  • in the case of finished products: one or more mill test certificates (MTC) 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, and of the facility where the processing or treatment operations are carried out,
  • if an MTC cannot be procured: a statement or declaration by the exporter or manufacturer confirming that the imported product does not contain any Russian steel or iron.
 
The prohibition to import or purchase of iron and steel inputs enters into application:
 
  • as of 30 September 2023 for products containing products other than those of CN codes 7207 11, 7207 12 10 or 7224 90,
  • as of 1 April 2024 for products containing products of CN code 7207 111,
  • as of 1 October 2024 for products containing products of CN codes 7207 12 102 or 7224 903.
 
In view of the new and the existing obligations connected with the imposed sanctions as well as the financial and criminal liability for non-compliance with them, we recommend that you thoroughly screen your potential contracting parties and the nature of your transactions.
 
Our experts would be glad to support you in identifying the risks and introducing adequate preventive measures. You are welcome to contact us.

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Alicja Szyrner

Attorney at law (Poland)

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