The EU already imposed restrictive measures (sanctions) against Russia in stages through Council Regulation (EU) No. 833/2014 of 31 July 2014, initially in response to the illegal annexation of Crimea and Sevastopol and the deliberate destabilization of Ukraine. After February 24, 2022, the EU massively expanded the sanctions in response to Russia's military aggression against Ukraine. In addition to financial sanctions and those relating to visas and residence rights as well as air traffic, these also restrict the movement of goods to a considerable extent. This includes the import of iron and steel products originating in Russia. Explicit proof was not previously required.
With the 11th sanctions package on June 26, 2023, the EU further tightened the current import ban on iron and steel products: from September 30, 2023, the import ban will also apply to products from third countries if iron and steel products originating in Russia were processed during production. The ban covers goods in accordance with Annex XVII of Regulation (EU) No. 833/2014. When importing the affected products, proof of the input materials used is now required.
German Customs has published a clarification on the proofs:
(...) According to Art. 3g para. 1 letter d) Regulation (EU) No. 833/2014, proof of the country of origin of the iron and steel pre-products used for the processing of the product in a third country must be kept available for the customs authorities at the time of import. The proof must be presented if requested by the customs office in individual cases.
In addition to the so-called Mill Test Certificates proposed by the Commission of the European Union, suitable supporting documents may also include:
- invoices,
- delivery bills,
- quality certificates,
- long-term supplier declarations,
- calculation and production documents,
- customs documents of the exporting country,
- business correspondence,
- production descriptions,
- declarations of the manufacturer or exclusion clauses in purchase contracts
from which the non-Russian origin of the primary products can be established are recognized.
We are always happy to answer any questions you may have.
Author
Fully qualified lawyer Inken Green
Product & Material Compliance Expert
