The prohibition on the import of Russian iron and steel products processed in a third country will come into effect from 30 September 2023. As the measure was introduced in the 2023 Regulations in April, there will be no exceptions or transitional period for any goods covered by the measure.
The full explanation can be found at here but in brief, any iron or steel products that may have been produced using materials of Russian origin are disallowed entry into the EU and the UK, irrespective of whether they would meet the current Rules of Origin regulations.
Evidence will need to be provided on demand. Traders should be prepared to have documentation available to demonstrate evidence of a good’s supply chain, which must be consistent with the prohibitions under the regulations.
Evidence requested to be provided through documentation could include:
- the country of origin of the iron and steel products processed in the third country (or third countries) after the fact
- the date that the iron and steel product left its country of origin
- the country(s) and facility(s) where processing has taken place
An example of evidence may include, but is not limited to, a Mill Test Certificate (MTC), or Mill Test Certificates (MTCs) where the relevant information cannot be summarised in a single document.
It is recommended that importers check with their suppliers and obtain evidence should this be asked for by HMRC on import entry. In the reverse scenario, exporters would need to be able to evidence to their EU customers of the same. We therefore recommend that a statement is inserted on the commercial invoice, or a separate declaration is issued making reference to the invoice number.
Example text
‘SUBJECT: RUSSIAN SANCTIONS. REGULATION EU 2023/1214 OF 23 JUNE 2023.
With reference to the goods contained in our invoice number <>, dated <> 2023, we hereby declare that such goods have not been manufactured, nor contain any measure of input materials as listed in Annex XVII (iron and steel products) of Regulation (EU) 2023/1214 (eleventh sanctions package against Russia) amending Regulation (EU) 833 / 2014.’
If you require any further information, please do not hesitate to contact us.