Update on sanctions against Russia. (EU legal framework)

Sharpened customs sanctions on iron and steel products

Regulation (EU) 2023/1214 of 23 June 2023 extended the existing sanctions against Russia in Regulation (EU) 2014/833. Article 3g (octies) of the latter regulation introduces an additional provision aimed at tightening sanctions against certain steel products. This addition takes effect on 30 September 2023.

These are goods from HS tariff chapters 72 (iron and steel) and 73 (iron and steel goods). A list of the relevant iron and steel goods can be found here. For now, some exceptions apply as mentioned in Article 3g (octies), point d.

Additional evidence in customs declaration has become essential

As of 30 September 2023, additional proof of origin (in addition to any certificate of origin) must be submitted with each customs declaration for the goods concerned. Only certificates of origin, EUR1 certificates and other documents for (non-)preferential origin are not accepted by Customs as proof of non-Russian origin.

The European Commission has published a Frequently Asked Questions document on this. For a full overview of the new regulations, please refer to the content of the above regulations and the frequently asked questions. According to this document, the ‘Mill Test Certificate’ (MTC) is a potentially suitable proof of origin. Despite this change taking effect, customs authorities have not yet disclosed which documents will be accepted as proof in addition to the MTC.

Request the right documentation in time

If the tightening of these sanctions affects your business, we advise you to contact your supplier/manufacturer/customer so that you can receive the correct documentation of the products in time and avoid importing illegal goods from Russia.

If you are a customer of ours and your company imports or has goods imported that may be subject to sanctions against iron and steel from Russia, your account manager will contact you.

We understand that you may have questions about this information. We therefore recommend that you read the European Commission’s FAQ document carefully. Still have questions? Our customs experts will be happy to help! Please L.Lockwood@gaston-schul.com for additional advice.