The EU and UK have banned Russian iron and steel products. Learn how this issue affects you in this post.
The European Union and the United Kingdom imposed restrictions on iron and steel goods manufactured in Russia. Read this article to find out how this situation impacts you.
What kinds of goods are prohibited from being imported from Russia due to the prohibition on iron and steel imports?
The two sections of the HS tariff that are most significantly impacted by the sanctions imposed on Russia are as follows:
Iron and steel in Chapter 72.
products made of iron, steel, and their alloys - Chapter 73.
Top Tip: It is of the utmost importance to make certain that you are employing the appropriate customs goods classification in order to safeguard your company from the potential liability of illegally importing items that were produced in Russia.
PLEASE NOTE: Items that have been processed, meaning that their classification or origin has been altered as a result of manufacture, assembly, or modification, are also not allowed to include any sanctioned components that originated in Russia.
What kinds of documentation are required to demonstrate that none of the imported items include any steel or iron that was produced in Russia?
Usually, you must provide one or more Mill Test Certificates (MTC) when purchasing processed commodities, but EU Member States and the UK may accept commercial alternatives.
In the words of one of our paid plan subscribers who is doing the customs declaration for many customers:
"We can declare Y824 but we must have evidence in the form of, mill certs, production certs or a certified declaration from the supplier indicating there is no Russian origin content in the steel. This is very important. This is a sanction condition. Failure to adhere is a criminal offence.
Import control (30-09-2023 - )
Excluding: Russian Federation (RU)
Y1 - Other conditions L 139 - Import/export allowed after control.
Y5 - Other conditions Y 824 - Import/export allowed after control.
Y7- Other conditions Y 859 - Import/export allowed after control.
Y9 - Other conditions - Import/export not allowed after control.
Additional information/Documents produced/Certificates and authorisations.
L139 Import authorisation by virtue of article 3g.7 of Council Regulation (EU) 833/2014.
Y824 Evidence of the country of origin of the iron and steel inputs used for processing of the product in a third country.
Y859 Goods entered the territory of the customs union of the EU and presented to customs authorities prior to the entry into force or to applicability date of the present sanction, whichever is latest (see Article 12e of Regulation (EU) No 833/2014)".
What is a Mill Certificate, how do I get one and what do I need to do?
What can you do to prepare?
Taking pre-emptive action is the best way to avoid problems with circumnavigation.
The first thing you need to do is check with your various suppliers to make sure that none of their goods include any iron or steel that originates from Russia and is thus subject to sanctions. It is incumbent upon you to do proper due diligence and to request that your suppliers do the same thing.
Book a meeting with us: www.customsmanager.org - Book Expert Call
I have more questions, where can I find more information?
The following questions are answered in the FAQ below:
Does the ban apply to all iron and steel products?
Are reusable packagings, e.g. containers, made of iron and steel containing goods also subject to the prohibition
Does the "purchase" also refer to restricted goods that are already released for free circulation within the EU or UK before entry into force of the relevant restrictive measures?
Does ‘import’ or "purchase" also refer to goods which are not purchased but are imported only temporarily for the purpose of repair and are re-exported to the third country after repair?
When do the prohibition start applying?
Does the application of the law also extend to products that were manufactured or processed in a third country before 30 September 2023?
Should the time of import be based on the first import into the EU, or should each import of the same goods be considered separately?
What do I need to know before I plan to import into the Union iron and steel products as listed in Annex XVII when processed in a third country?
Is the mill test certificate (MTC) the only document that is accepted as evidence that the goods to be imported in the Union do not incorporate iron and steel inputs aI originating in Russia?
Where do I need to indicate the MTC and/or any other document used as evidence?
Is the evidence needed for all processing operations throughout the whole supply chain or for the processing in the last country before the import into the EU or UK?
For more questions, please contact us.
Download Our Detailed EU Guide on Steel & Iron Sanctions Against Sanctions, including an updated FAQ: https://www.customsmanager.info/post/eu-steel-iron-import-sanctions-against-russia
Download Our Detailed UK Guide on Steel & Iron Sanctions Against Sanctions, https://www.customsmanager.info/post/uk-guide-sanctions-against-russian-iron-and-steel
Why Customs "Origin" is NOT enough - Example
Imagine China purchasing raw iron from Russia. China then processes this into Iron bars. From an origin perspective, this may turn the iron bar to be "of Chinese origin". These bars are sent to the USA, where they are processed into steel rings, which may change the non-preferential origin again to become a U.S. product. This U.S. product is then offered for sale to customers in the European Union or the United Kingdom.
ypical Customs origin papers, certificates of origin, and other paperwork for non-preferred and preferential origin are NOT recognised as evidence of non-Russian origin.
Even if the steel comes from China and the rings from the US, its origins are in Russia, and it is against the law to import certain goods from that country.
The European Union and the UK imposed restrictions on iron and steel goods manufactured in Russia. The sanctions are most significant in the HS tariff sections for iron and steel and products made of iron, steel, and their alloys. To ensure compliance, companies must use appropriate customs goods classification and provide Mill Test Certificates (MTC) when purchasing processed commodities. These certificates provide crucial information on a material's origin, composition, mechanical properties, and chemical analysis. Pre-emptive action is advised, including checking with suppliers to ensure no iron or steel from Russia is included. Customs Manager Ltd can help you prepare. Please get in touch.
More Information & Links
-> UK: Guidance Steel & Iron Import Sanctions Against Russia
Dive deeper into the subject with expert guidance
-> EU: Guidance on Steel & Iron Import Sanctions Against Russia
Dive deeper into the subject with expert guidance
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