Iron & Steel Sanctions from Russia: FAQ on "Mill Test Certificates"

Answers to Common Questions Regarding Mill Certificates and Sanctions Compliance

Why are mill certificates essential now for steel and iron imports into the EU, UK or U.S.?

Mill Test Certificates (MTC) are now required to demonstrate that steel and iron products do not come from Russia. When discussing imports and penalties related to sanctions items, mill certificates have been mentioned. In the EU, for example, this is specified in Annex XVII of the Council Regulation (EU) 2022/1904 of October 6, 2022. The MTC's ability to ensure COMPLIANCE with import rules by exposing the country of origin is, in the end, its most crucial characteristic.

Are MTC the same as MCs or MTRs?

Not really. But overall, for sanctions compliance purposes, the Mill Test Certificate (MTC), or just a Mill Certificate (or a Material Test Report (MTR)), is a quality assurance certification used in producing and inspecting materials.

Where are MTCs commonly found?

They are particularly helpful in the manufacturing, construction, and metalworking industries. An MTC mainly provides vital information on the properties and grade of a specific batch or lot of material, generally steel or other metals or other essential materials used for construction or engineering projects.

Example of prohibitive law requiring Mill Certificates: The EU

According to Article 3g of Council Regulation (EU) No 833/2014 of July 31, 2014, which relates to restrictive measures given Russia's actions destabilising the situation in Ukraine, the following are prohibited:

Iron and steel products listed in Annex XVII must be brought into the Union in one of the following ways:

• (a) directly or indirectly, if they are made in Russia or have been exported there;

• (b) directly or indirectly, if they are purchased there;

• (c) transported, whether they are made in Russia or are being exported there to any other country.

• d) Import or purchase, directly or indirectly, the iron and steel products mentioned in Annex XVII that are originating from Russia, as well as the items described in that Annex when they are processed in a third country.

What ar the primary components and goals of a mill certificate?

Trackability: The mill certiciate often contains information that makes it possible to track an item back to its country of origin or the world of customs. This includes the producer's details and the content's production location and date.

Identification: A Material Technical Correction is built upon the basic data of a material. This includes details on the material's kind, grade, lot number, heat number, and any applicable measurements or parameters.

Chemical Composition: The material's chemical composition is often mentioned in the MTC. Knowing this information is crucial to ensuring the material meets all standards. This section contains a list of the percentages of each element that may be found in the material.

-> Mechanical properties: The hardness, elongation, yield strength, tensile strength, and other relevant properties of the material are described in depth in this section. These qualities help assess a material's strength and suitability for a particular use.

-> Details of Heat Treatment: Any heat treatment operations, such as annealing or quenching, that the material has experienced will be included in the MTC. Heat treatment has the potential to change the material's properties significantly.

-> Results of Tests and Inspections: The material was subjected to several tests and inspections during the manufacturing and quality control processes. The results are included in the Material Test Certificate (MTC). Standard tests include tensile testing, impact testing, chemical analysis, and non-destructive testing (such as radiography or ultrasonic testing). These results verify that the content meets the required requirements and specifications.

-> Conformity with Standards: The MTC indicates if the product complies with relevant industrial standards, such as ASTM (American Society for Testing and Materials) or EN (European Norms). You may also provide any applicable standards or guidelines.

-> Approved Signatures and Stamps: To ensure its validity, the MTC is often signed and stamped by approved people, such as accredited laboratories or quality control inspectors. This lends more credibility to the paper.

What is a mill certificate used for?

A mill certificate ensures that the materials utilised in a project or product meet all relevant quality standards and specifications, which is essential information for clients, engineers, and inspectors. It helps ensure the reliability and security of parts, equipment, and structures in many industries. Without an MTC, it might be challenging to verify the properties and calibre of the materials, which raises the possibility of mishaps and issues with quality control throughout the construction and production processes.

What is a Mill Test Certificate?

A mill certificate is a quality assurance certification used in the metals industry to quantify the chemical and physical properties of a material. It verifies that a metal product (such as one made of brass, aluminium, steel, titanium, or another alloy) satisfies the order's specifications. They provide crucial information on a variety of topics, including the origin, composition, mechanical properties, and chemical analysis of materials. Mill Certificates provide stakeholders the knowledge they need to control risks, make wise decisions, and maintain high standards of quality.

How can I get a Mill certificate?

Before the items are sent out of the facility, the producer typically provides the material test report, also known as the mill test report/certificate. However, depending on certain criteria, a third-party quality inspection organisation could sometimes release the report.

What to do in case of a query by the authorities?

Throughout the whole process of obtaining import clearance, the information that is provided on the Mill Test Certificate belongs to the importer. Please be aware that during an inquiry, customs may ask for more information, such as the date or dates of the transit, so please prepare yourself for this possibility. Contact the Customs Manager's experts to help you implement these changes.

How we can help

To inquire about compliance with sanctions regulations or how to set up a functioning system of compliance with sanctions and export controls, please email info@customsmanager.org or book a free expert call.

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