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Stay Ahead of the Game: Key Insights from The Export Controls & Sanction Manager Edition 8 for Week 50 of 2023 - the last of 2023! Welcome to the last "The Export Controls & Sanctions" Manager Magazine of the year. It's the perfect resource to help you stay fully compliant with export controls and sanctions laws across multiple jurisdictions. Don't miss out on our winter-themed edition and be confident in your compliance efforts - take a look today. We are a day late because we took a little more time to include the information on the latest sanctions packages of the EU and UK. We are taking a break until 9 January 2024, and we look forward to serving you then and covering everything that happened between 21 December 2023 and 8 January 2024! Wishing you a joyous and festive Merry Christmas and a prosperous and fulfilling Happy New Year in the year 2024! What is this all about? Period covered 13.12 -20.12.2023 Content Due Diligence & AML Export Controls Updates U.S. Export Controls EU Export Controls UK Export Controls Sanctions Updates EU Sanctions UK Sanctions U.S. Sanctions What to do if I have questions regarding these updates? Sources Unlock all exclusive posts and make sure you stay fully up-to-date. Access Our NEW FAQ to answer all your questions: https://www.customsmanager.info/plans-pricing What's New in 2024? 1. Weekly Wrap Up Are you aware of the latest changes in customs and export controls? Join us for our new weekly online call, where you can stay ahead of the game. After the call, we offer an exclusive learning opportunity that covers crucial customs and global trade subjects in our weekly Lunch and Learn. Don't let this opportunity pass you by - registration is now OPEN! Find out more https://www.customsmanager.info/post/new-in-2024-understanding-customs-export-control-changes-wrap-up-call-lunch-n-learn Book here: www.customsmanager.org/events 2) Lunch n' Learn As a paid subscriber, you can access an exclusive 30-minute "Lunch 'n Learn" session every week for free, saving you 50 GBP (regular price for non-premium paid plan subscribers). This is a live training session regarding customs and/or export controls/sanctions and the agenda can be determined by the audience (but we do propose an agenda below). During this session, we will explore a specific topic in more depth every week. Find out more https://www.customsmanager.info/post/new-in-2024-understanding-customs-export-control-changes-wrap-up-call-lunch-n-learn Book here: www.customsmanager.org/events Due Diligence & AML For all updates, see: https://www.customsmanager.info/all-news/categories/due-diligence NEW BLOG EXPLAINER Trade Compliance: A Comprehensive Guide for Custom and Global Trade Managers to Identify Red Flags We have written a blog to assist you in discovering the secrets to navigating the complex landscape of customs and global trade management. The blog is a comprehensive guide that equips trade managers with the knowledge and tools they need to ensure compliance and avoid potential pitfalls. Read it here. Export Controls Updates To make sure you never miss an export control update, bookmark https://www.customsmanager.info/all-news/categories/export-controls ⇒ EU Export Controls Updated EU Dual-Use Control List Comes Into Force” The European Commission’s 2024 list of controlled dual-use items (proposed on 15 September 2023) has now come into force. The updates concern the control parameters for manufacturing equipment, high-performance computers and lasers, propulsion motors for submersible vehicles, and aircraft engines. We are proving you all the details and information of the changes so you can export compliantly Details: https://www.customsmanager.info/post/eu-2023-update-of-the-eu-control-list-of-dual-use-items ⇒ UK Export Controls Report of the 2023 UK ECJU Export Control Symposium The 2023 ECJU Export Control Symposium was a highly anticipated event that brought together experts, policymakers, and industry leaders in the field of export control. We report on the main results and share PowerPoint Presentations for download. https://www.customsmanager.info/post/report-of-the-2023-uk-ecju-export-control-symposium ⇒ U.S Export Controls 13 companies added to the U.S. EAR Unverified List See names and updated here: https://www.customsmanager.info/post/u-s-export-controls-the-unverified-list Implementation of the Chemical Weapons Convention Legitimate Commercial Chemical, Biotechnology, and Pharmaceutical Activities Involving Schedule 1 Chemicals (including Schedule 1 Chemicals produced as Intermediates) During Calendar Year 2023. Date: 20 Dec 2023; Permalink Sanctions Updates The EU, UK and US implement extensive sanctions laws. These rules provide processes for producing lists of individuals and businesses subject to asset freeze targets and financial and investment restrictions. Businesses must stay up to date with the latest sanctions rules to avoid accidental non-compliance. Read the collection of all articles we have written on this topic here https://www.customsmanager.info/all-news/categories/sanctions ⇒ EU Sanctions Updates EU Sanctions Against Russia: Content of the 12th Sanctions Package The 12th round of sanctions against Russia has been adopted by the EU. It applies from 1 January 2024. This package aims to address loopholes, fight sanctions circumvention, and impose more import and export limitations on Russia. https://www.customsmanager.info/post/12th-sanctions-package-of-the-eu-against-russia EU Sanctions Against Russia: Full Guide (Updated) Get a complete overview of EU sanctions against Russia, including the latest updates and a breakdown of each sanctions package. Date of last update 19.12.2023 https://www.customsmanager.info/post/eu-russia-sanctions-our-complete-overview-for-businesses EU: Consolidated Sanctions List of Persons, Groups, Entities, and Organisations (Sanctions) - Update Discover the ultimate resource for EU sanctions: Download the consolidated list of persons, groups, and entities subject to sanctions. Date of last update 20.12.2023 https://www.customsmanager.info/post/eu-consolidated-financial-sanctions-list EU Takes Action Against Sanctions Violations: Two New Initiatives Funded Two new measures of the "Freeze and Seize" Task Force have reached political approval. We explain what this is all about. https://www.customsmanager.info/post/eu-takes-action-against-sanctions-violations-two-new-initiatives-funded ⇒ UK Sanctions Updates What You Need to Know About the UK's New Sanctions Against Russia Regulations 2023: The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) and The Russia (Sanctions) (Events) (Amendment) (No. 5) of Russia (Sanctions) (EU Exit) Regulations 2019 were amended by the UK government on December 14, 2023 to further restrict goods, technology, and funding sources that the UK government believes could be used to support Russia's war against Ukraine. The majority of the changes went into effect on December 15, 2023, with a few going into effect on December 26, 2023, and January 1, 2024. https://www.customsmanager.info/post/what-you-need-to-know-about-the-uk-s-new-sanctions-against-russia Joint-Stock Commercial Bank Novikombank entry added, 27 entries amended on the consolidated list (19.12.2023) The Joint-Stock Commercial Bank Novikombank (Group ID: 16337)has been added and 27 entries have been amended under the Russia financial sanctions regime. The Joint-Stock Commercial Bank Novikombank is now subject to an asset freeze, prohibitions on correspondent banking relationships and trust services sanctions. Details of the entity listings and amendments here. 7 entries added to the consolidated list On 13 December 2023 the Foreign, Commonwealth and Development Office updated the UK Sanctions List . 7 entries have been added to the Counter-Terrorism (International) financial sanctions regime and are now subject to an asset freeze. You can access all the regimes that the uk has issued sanctions for here including links to latest updates. OFSI General Licences updated On 15 December 2023, OFSI updated the following General Licences to also permit activity that would otherwise breach the prohibitions in Regulation 17A of the Russia Regulations: Transactions Related to Agricultural Commodities Including the Provision of Insurance and Other Services Payments to Utility Companies for Gas and Electricity by UK Designated Persons who Own Payments to Companies House Permitted Payments to UK Insurance Companies Charities and Interim Managers and Trustees Russia Travel for UK Nationals Provision of Navigational Data to Civilian Aircrafts for Flight Safety Prior Obligations LCIA Payments Payment to Water Companies for Water and Sewage Legal Services Emergency Payment(s) Directly or via an Intermediary to Belaeronavigatsia for Air Traffic Services Details here and access to all licences New UK Russia import sanctions updated UK import sanctions against Russia were updated to reflect the implementation of new import sanctions measures relating to certain metals and diamond products. Our blog entry provides an overview of the import prohibitions in force on certain goods imported into the UK, including Northern Ireland, that have originated in or have been consigned from the territory covered by what is now the Russian Federation and non-government-controlled Ukrainian territory. It also sets out the licensing process for traders looking to import goods subject to prohibitions. Russia Import Prohibition UK Guidance on third-country processed iron and steel measures Updated Find out about the guide to relevant Russian iron and steel processed in third countries only, and the evidence traders need to provide to demonstrate compliance. It does not discuss other prohibitions (including other measures related to Russian iron and steel, except for the section on reuseable packaging under the GeneralTrade Licence). https://www.customsmanager.info/post/uk-guide-sanctions-against-russian-iron-and-steel Iran: First Designations under new UK sanctions law The first round of sanctions under the new government targets the commander of Iran's Quds Force, the Islamic Revolutionary Guard Corps (IRGC), as well as anybody connected to Iran's support of Palestinian Islamic Jihad and Hamas. In agreement with the US, the new sanctions also place more limitations on Iran's drone project and shipping. The UK now has a great deal more authority to stop Iran's hostile actions both domestically and internationally thanks to the new sanctions framework. Read More.... The imposition of further sanctions by the UK on Iran has greatly increased the UK's ability to hold Iran and its leaders responsible. OFSI publishes annual review 2022-2023 OFSI has published its annual review for the financial year 2022-2023, outlining (OFSI blog post): new sanctions which have been introduced in the last year, including new ransomware sanctions; 800 designated persons were added to the consolidated list; as of April 2023, OFSI’s enforcement unit had 172 cases under live investigation; OFSI recorded 473 suspected breaches of financial sanctions; Read the blogpost ⇒ U.S. Sanctions Updates U.S. Sanctions on Russia: A Look at the US Treasury's Impact Analysis The US Treasury described how sanctions impact Russia's economy and offered policy recommendations on how to react. Read here Treasury Targets Transnational Corruption OFAC sanctioned two former Afghan government officials — Mir Rahman Rahmani (M. Rahmani) and his son, Ajmal Rahmani (A. Rahmani), collectively known as “the Rahmanis” — for their extensive roles in transnational corruption, as well as 44 associated entities. Press release Designations The US names people and organisations associated with Russia's military-industrial complex. Targeting third-country suppliers and procurement networks, OFAC has identified more than 150 people and organisations for allegedly providing Russia's military-industrial base. These people and organisations include: a network of PRC-based companies headed by Hu Xiaoxun that purchases weapons made in China and supplies Russia with electronics and satellite photography technology; 7 Turkish companies that reportedly sent top-priority goods to producers in Russia; 8 UAE-based companies that have supplied Russia with materials, parts, and components for aircraft Designations Press Release Russia-related Designations and Designations Updates; Issuance of Russia-related General Licenses OFAC is issuing Russia-related General License 79, "Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on December 12, 2023," and Russia-related General License 80, "Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Highland Gold Mining Limited." See more U.S. And UK Target Additional Hamas Finance Officials and Representatives OFAC imposed a fourth round of sanctions on Hamas since the October 7 terrorist attack on Israel. The action targets key officials who perpetuate Hamas’s violent agenda by representing the group’s interests abroad and managing its finances. OFAC closely coordinated with the United Kingdom to concurrently designate several key Hamas officials. Details here Other OFAC action Please see below for details on these points U.S. and U.K. Target IRGC-QF Support to Hamas and Other Proxy Groups Treasury Sanctions Human Smuggling and Drug Trafficking Organization Operating on Southwest Border Malas Manas chart More details Burma General Licences 3 and 4 in the Federal Register Publication of Burma Sanctions Regulations Web General Licenses 3 and 4 in 88 FR 87714, 19 Dec 2023. OFAC is publishing two general licenses (GLs) issued pursuant to the Burma Sanctions Regulations: GLs 3 and 4, each of which was previously made available on OFAC's website. GLs 3 and 4 were issued on March 25, 2021. Publication of Syria-Related Sanctions Regulations Web General Licenses 1, 2, and 3 in 88 FR 87715, 19 Dec 2023 OFAC is publishing three general licenses (GLs) issued pursuant to the Syria-Related Sanctions Regulations: GLs 1, 2, and 3, each of which were previously made available on OFAC's website. GLs 1, 2, and 3 were issued on October 14, 2019. Designation as Terrorist or Global Terrorist Mohamed Ali Nkalubo and Ahmed Mahamud Hassan Aliyani Date: 20 Dec 2023; Permalink Update of the latest SDN list (20.12.2023) See here: https://www.customsmanager.info/post/u-s-sanctions-ofac-s-specially-designated-nationals-sdn-list-update What if I have a question regarding these updates We invite you to use the chat function available on www.customsmanager.org to ask any questions related to this update. Our skilled team of export control and sanctions managers will be happy to provide you with the information you need within 24 hours. Sources EU Official Journal of the EU DG TRADE Website Social Media (LinkedIn, Twitter, etc). Information on the National Export Control & Sanctions Website of Member States U.S. Bureau of Industry and Security (BIS) Department of Commerce Office of Foreign Asset Control (OFAC) Social Media (LinkedIn, Twitter, etc). UK Information on gov.uk Information on legislation.gov.uk Department of Business and Trade Social Media (LinkedIn, Twitter, etc). Other United Nations (Sanctions) Social Media (LinkedIn, Twitter, etc). About Customs Manager’s Customs & Global Trade Intelligence Services The Premium Professional Legislative Monitoring Service (PLM) is a research and curation service which checks for legislative updates from official government websites based on the selected jurisdictions and topics. Paid Plan subscribers can access regular law change notifications to ensure they never miss a significant legal change on www.customsmanager.info – a website dedicated to customs & trade intelligence. At the same time, they save valuable time by engaging our dedicated trade specialists to carry the monitoring out for them. Premium subscribers also unlock all content on the Customs Manager’s Ltd. website, including our Customs & Trade Blog on www.customsmanager.info , providing vital thought leadership development services to empower them to trade effectively, efficiently and, of course, compliantly, across borders. Premium Subscribers can add jurisdictions and topics for an additional charge. About Customs Manager Ltd. We aim to empower people with import, export and transport responsibilities with helpful advice, insightful training and relevant trade intelligence services. We devote all our passion and energy to helping businesses grow faster cross-border. Working with us means having your own multilingual Customs Manager on standby to help you trade effectively, efficiently and, of course, compliantly wherever you want to go. Includes Brexit support and the ability to lodge customs declarations + Rules of Origin Stay in Touch · Website: www.customsmanager.org · E-Mail: info@customsmanager.org · YouTube: https://www.youtube.com/c/CustomsManagerLtd · Twitter: @customsmanager · Linked In: https://www.linkedin.com/company/69768402/admin/ Important Notice Customs Manager Ltd. owns the copyright in this document, except for external documents and links we refer to or make available. You are not allowed to use this information in any way that infringes its intellectual property rights. You may have to hold a valid licence to use this information. A licence can be obtained by becoming a Paid Plan subscriber to the Customs Managers’ Customs & Trade Intelligence service, also known as Professional Legislative Monitoring (PLM). As a Paid Plan subscriber, you may download and print this information which you may then use, copy or reproduce for your internal non-profit-making purposes. However, you are not permitted to use, copy or reproduce this information to profit or gain. In addition, you must not sell or distribute this information to third parties, not members of your organisation, whether for monetary payment or otherwise. This information is intended to serve as general guidance and not constitute legal advice. The application and impact of laws can vary widely based on the specific facts involved. This information should not be used as a substitute for consultation with professional legal or other competent advisers. Before making any decision or taking action, consult a Customs Manager Ltd. professional. In no circumstances will Customs Manager Ltd be liable for any decision made or action taken in reliance on the information contained within this document or for any consequential, special or similar damages, even if advised of the possibility of such damages.

The 2023 ECJU Export Control Symposium was a highly anticipated event that brought together experts, policymakers, and industry leaders in the field of export control. We report on the main results and share PowerPoint Presentations for download. What is a UK ECJU Export Control Symposium? This symposium aimed to facilitate discussions on emerging trends, challenges, and opportunities in the ever-evolving landscape of export control regulations. Arne Mielkem, MD of Customs Manager Ltd and certified export control specialist, took part in panel discussions, informative presentations, and networking opportunities that allowed him to stay updated on the latest developments and exchange ideas with fellow professionals. Why do export controls matter in the UK? Export control is of utmost importance in international trade as it helps ensure the security and protection of a country's strategic assets, sensitive technologies, and national interests. By regulating the export of goods, technologies, and services, countries can prevent the proliferation of weapons of mass destruction, curb terrorism financing, and maintain a level playing field for businesses. Moreover, export control helps countries maintain their economic competitiveness by safeguarding intellectual property and preventing the unauthorized transfer of sensitive technologies to adversaries. Overall, a robust and effective export control system is crucial for maintaining global security and fostering fair and sustainable international trade. What were the key objectives of the UK ECJU Export Control Symposium? The symposium aims to address these pressing issues and facilitate discussions on best practices and strategies for strengthening export control systems. Key objectives include sharing knowledge and experiences on effective export control measures, exploring innovative technologies and tools for enhancing export control capabilities, and fostering collaboration among countries to improve information sharing and coordination. By focusing on these objectives, the symposium seeks to contribute to the global effort in maintaining global security and promoting a level playing field for international trade Main Outcomes of the UK ECJU Export Control Symposium During the symposium, various topics and issues were addressed in plenary and in workshops. These included the identification of best practices and lessons learned in implementing export control measures, which aimed to improve the effectiveness and efficiency of these measures. Additionally, strategies and initiatives were developed to enhance export control capabilities and address emerging challenges in the global trade landscape. The establishment of networks and partnerships among participating countries was also emphasized to foster ongoing collaboration and information sharing. Furthermore, recommendations and guidelines were formulated to strengthen international export control systems and frameworks. Finally, the main outcomes and conclusions reached by participants were highlighted, shedding light on the progress made and future directions in the field of export control. Key topics and issues addressed during the symposium WORKSHOP 1: The Strategic Export Licensing Criteria and the application assessment process. In this workshop, we focused on the Strategic Export Control Licencing Criteria the levels of risk in trading in overseas markets and the need for due diligence. Download the PowerPoint Presentation delivered at this workshop. WORKSHOP 2: Protecting classified information and material MOD Form 680s, exhibition clearances and Private Venture security grading. This session provided an overview of the Form 680 process, when and why exhibition clearances are needed (such as open licences), and PV security grading of items not subject to a government contract. WORKSHOP 3: Understanding unnecessary delays to licence applications and how to get them right the first time. This session covered incomplete essential fields; incorrect or absent supporting documentation, end-user undertaking errors, incorporation concerns; excessive quantities Download the PowerPoint Presentation delivered at this workshop. WORKSHOP 4: HMRC - Why Goods are Intercepted by Customs, Enforcement Action, and Outcomes WORKSHOP 5: Navigating the control lists Download the PowerPoint Presentation delivered at this workshop. WORKSHOP 6: Update on the future system for processing licences: The LITE programme This session provided an update on the development of the new Licensing System to replace SPIRE. Download the PowerPoint Presentation delivered at this workshop. WORKSHOP /: US Export Control Compliance for Beginners This session provided an overview of US export control regulations covering ITAR, EAR and the Export Control Review. It covered Relevance of ITAR and EAR to UK exporters Explanation of key terminology used in ITAR and EAR regulations Key challenges associated with ITAR Key challenges associated with EAR Download the PowerPoint Presentation delivered at this workshop. WORKSHOP 8: US Export Control Compliance for Intermediate This session provided an overview of U.S. Export Controls, the current state of ECR, and proposed legislative changes. It covered Is the item under the EAR or the ITAR and what is the impact? Developing a framework for order of review from USML to 600 series to general CCL Understanding when and how to apply the “specifically” designed test Grasping how classification under ITAR, 600 series or general CCL impacts your business Developing a framework to apply the “de minimis” and direct product rules under the EAR Download the PowerPoint Presentation delivered at this workshop. Takeaway The 2023 ECJU Export Control Symposium was a gathering of experts, policymakers, and industry leaders to discuss emerging trends, challenges, and opportunities in export control regulations. Export control is crucial for maintaining global security and fostering fair international trade. Key objectives of the symposium included sharing best practices, exploring innovative technologies, and fostering collaboration among countries. Key topics addressed included strategic export licensing criteria, protecting classified information and material, understanding delays to license applications, HMRC workshops, technical assessment unit workshops, and the future system for processing licenses. The symposium also covered US export control compliance for beginners and intermediates, covering topics such as ITAR, EAR, and the Export Control Review. 4-In-1 Support Services: How to get more support 1. Customs & Global Trade Updates (Fee Subscription): www.customsmanager.info 2. Customs & Global Trade Consultancy & Advice (Free First Call): https://www.customsmanager.org/consultancy 3. Customs & Global Trade Training & Education: https://www.customsmanager.org/education-training 4. Compliant & efficient UK Customs Clearance: https://www.customsmanager.org/customs-agent Connect with us on socials LinkedIn: https://www.linkedin.com/company/customs-manager-ltd/ X: @customsmanager YouTube: https://www.youtube.com/c/CustomsManagerLtd Get in Touch · Website: www.customsmanager.org · E-Mail: info@customsmanager.org About Customs Manager’s Customs & Global Trade Intelligence Services The Premium Professional Legislative Monitoring Service (PLM) is a research and curation service which checks for legislative updates from official government websites based on the selected jurisdictions and topics. Paid Plan subscribers can access regular law change notifications to ensure they never miss a significant legal change on www.customsmanager.info – a website dedicated to customs & trade intelligence. At the same time, they save valuable time by engaging our dedicated trade specialists to carry the monitoring out for them. Premium subscribers also unlock all content on the Customs Manager’s Ltd. website, including our Customs & Trade Blog on www.customsmanager.info , providing vital thought leadership development services to empower them to trade effectively, efficiently and, of course, compliantly, across borders. Premium Subscribers can add jurisdictions and topics for an additional charge. About Customs Manager Ltd. We aim to empower people with import, export and transport responsibilities with helpful advice, insightful training and relevant trade intelligence services. We devote all our passion and energy to helping businesses grow faster cross-border. Working with us means having your own multilingual Customs Manager on standby to help you trade effectively, efficiently and, of course, compliantly wherever you want to go. Includes Brexit support and the ability to lodge customs declarations and making sense of rules of origin, customs classification and customs valuation to make but a few. Important Notice Customs Manager Ltd. owns the copyright in this document, except for external documents and links we refer to or make available. You are not allowed to use this information in any way that infringes its intellectual property rights. You may have to hold a valid licence to use this information. A licence can be obtained by becoming a Paid Plan subscriber to the Customs Managers’ Customs & Trade Intelligence service, also known as Professional Legislative Monitoring (PLM). As a Paid Plan subscriber, you may download and print this information which you may then use, copy or reproduce for your internal non-profit-making purposes. However, you are not permitted to use, copy or reproduce this information to profit or gain. In addition, you must not sell or distribute this information to third parties, not members of your organisation, whether for monetary payment or otherwise. This information is intended to serve as general guidance and not constitute legal advice. The application and impact of laws can vary widely based on the specific facts involved. This information should not be used as a substitute for consultation with professional legal or other competent advisers. Before making any decision or taking action, consult a Customs Manager Ltd. professional. In no circumstances will Customs Manager Ltd be liable for any decision made or action taken in reliance on the information contained within this document or for any consequential, special or similar damages, even if advised of the possibility of such damages.

Breaking Down the UK's Latest Sanctions on Russia: What You Need to Know

Understanding the Unverified List and Its Impact on U.S. Export Controls: Latest Changes Explained. Date of Last Update 20.12.2023

An Overview of the Updated Sanctions OFSI (Office of Financial Sanctions Implementation) General Licences in the UK. Date of Last Update20.12.2023

Find here the latest list of Common High Priority sanctioned goods to which businesses should apply particular due diligence and which third countries must not re-export to Russia.

The Economically Critical Goods List is comprised of mainly industrial goods subject to EU’s restrictive measures for which anomalous trade flows through certain third countries to Russia have been observed.

The EU has sanctioned Russia by ever-expanding legislation - in so-called "packages". We explain what was introduced under each package.

The US Treasury described how sanctions impact Russia's economy and offered policy recommendations on how to react.

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. Iron and Steel Prohibited 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. 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. Documentation requirements 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 EU, you may code Y824, but you must have evidence in the form of a mill certificate or similar, production certs or a certified declaration from the supplier indicating there is no Russian-origin content in the steel. This is critical. This is a sanction condition. Failure to adhere is a criminal offence." Navigating the UK's Sanctions on Russian Iron and Steel: A Comprehensive Guide. Read our guide on the UK Ban on Russian iron and steel processed in third countries only and the evidence traders need to provide to demonstrate compliance. https://www.customsmanager.info/post/uk-guide-sanctions-against-russian-iron-and-steel What is a Mill Certificate, how do I get one, and what do I need to do? Find our details here: https://www.customsmanager.info/post/iron-steel-mill-certificate-what-is-it-and-how-can-i-get-one 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. 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? Download FAQ here: https://www.customsmanager.info/post/eu-faq-on-the-ban-on-iron-and-steel-imports-from-russia 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 Conclusion 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 https://www.customsmanager.info/post/uk-guide-sanctions-against-russian-iron-and-steel -> EU: Guidance on Steel & Iron Import Sanctions Against Russia Dive deeper into the subject with expert guidance https://www.customsmanager.info/post/eu-steel-iron-import-sanctions-against-russia About Customs Manager’s Customs & Global Trade Intelligence Services The Premium Professional Legislative Monitoring Service (PLM) is a research and curation service which checks for legislative updates from official government websites based on the selected jurisdictions and topics. Paid Plan subscribers can access regular law change notifications to ensure they never miss a significant legal change on www.customsmanager.info – a website dedicated to customs & trade intelligence. At the same time, they save valuable time by engaging our dedicated trade specialists to carry the monitoring out for them. Premium subscribers also unlock all content on the Customs Manager’s Ltd. website, including our Customs & Trade Blog on www.customsmanager.info , providing vital thought leadership development services to empower them to trade effectively, efficiently and, of course, compliantly, across borders. Premium Subscribers can add jurisdictions and topics for an additional charge. About Customs Manager Ltd. We aim to empower people with import, export and transport responsibilities with helpful advice, insightful training and relevant trade intelligence services. We devote all our passion and energy to helping businesses grow faster cross-border. Working with us means having your own multilingual Customs Manager on standby to help you trade effectively, efficiently and, of course, compliantly wherever you want to go. Includes Brexit support and the ability to lodge customs declarations + Rules of Origin Stay in Touch · Website: www.customsmanager.org · E-Mail: info@customsmanager.org · YouTube: https://www.youtube.com/c/CustomsManagerLtd · Twitter: @customsmanager · Linked In: https://www.linkedin.com/company/69768402/admin/ Important Notice Customs Manager Ltd. owns the copyright in this document, except for external documents and links we refer to or make available. You are not allowed to use this information in any way that infringes its intellectual property rights. You may have to hold a valid licence to use this information. A licence can be obtained by becoming a Paid Plan subscriber to the Customs Managers’ Customs & Trade Intelligence service, also known as Professional Legislative Monitoring (PLM). As a Paid Plan subscriber, you may download and print this information which you may then use, copy or reproduce for your internal non-profit-making purposes. 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The EU has answered detailed questions on iron and steel imports from Russia. Here are the frequently asked questions and answered.