The European Union’s (EU) eleventh package of sanctions against Russia tightens the restrictions on imports of steel and iron products by requiring importers of sanctioned steel and iron goods processed in a third country to prove that the inputs used do not come from Russia.
The European Commission adopted Regulation (EU) 2023/1214 amending Regulation (EU) 833/2014 “concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine.” Article 3g establishes that the importation of steel and iron products listed in Annex XVII are prohibited when processed in a third country incorporating steel or iron originating in Russia.
The European Commission published guidance on using the Mill Test Certificate(s) (MTCs) to prove the origin of the steel and iron. The importer is responsible for the information provided in the MTCs. and Customs authorities may require additional evidence such as supplementary separate MTCs for different transformation steps the product has undergone.
These restrictions are effective from:
- September 30, 2023: products of Annex XVII containing products other than those of CN codes 7207 11, 7207 12 10, or 7224 90;
- April 1, 2024: products of Annex XVII containing products of CN code 7207 11; and
- October 1, 2024: products of Annex XVII containing products of CN codes 7207 12 10 or 7224 90.
(EU) 2023/1214 can be found here:
EUR-Lex - 32023R1214 - EN - EUR-Lex (europa.eu)
The European Commission’s Consolidated FAQs can be found here:
