New EU Sanctions on Russian Iron & Steel Imports
In June 2023, the European Union (EU) introduced new sanctions measures aimed at restricting the import of iron and steel products from Russia. These measures come as a response to Russia’s actions, which have contributed to the destabilisation of the situation in Ukraine. It’s essential for businesses involved in importing or dealing with iron and steel products to understand these sanctions to ensure compliance and avoid potential penalties.
In this blog post, we’ll break down the key points from eCustoms Notification 25/2023 and explain what businesses need to do to navigate these new restrictions effectively.
Understanding the Sanctions
The new sanctions introduced by the EU are outlined in Council Regulation (EU) 2023/1214. These measures prohibit the import of iron and steel products that either originate in Russia or have been exported from Russia. The specific list of products subject to these sanctions is found in Annex XVII of the Regulation. This Annex corresponds to tariff headings 7206-7229 within Chapter 72, and the full Chapter 73 of the Combined Nomenclature (CN) codes. These sanctions came into effect on September 30, 2023.
The EU has extended this prohibition to include imports or purchases of iron and steel products processed in a third country that incorporate iron and steel products originating in Russia. This extension ensures that the sanctions cover a broader range of products.
Key Dates to Remember
For products classified under CN codes 7207 11, the prohibition applies from April 1, 2024. For products classified under CN codes 7207 12 10 and 7224 90, the prohibition becomes effective on October 1, 2024.
Article 3g(1)(d) of the Regulation establishes an obligation for importers in the EU. Importers are required to provide evidence of the country of origin of the iron and steel inputs used in the processing of products in a third country. This evidence is vital to confirm that the primary products used in processing are not of Russian origin.
To meet this obligation, importers should have appropriate documentation ready, and it should be made available to customs if requested. Uploading these documents as supporting evidence at the time of lodging the customs import declaration can help prevent delays in the customs process.
Various documents are considered acceptable as evidence of the country of origin of the iron and steel inputs used in processing. These include:
- Mill Test Certificates
- Delivery notes
- Quality certificates
- Long-term supplier’s declarations
- Calculation and production documents
- Customs documents from the last country where processing occurred
- Business correspondence
- Production descriptions
- Declarations of the manufacturer
- Exclusion clauses in purchase contracts showing the non-Russian origin of the primary products.
Understanding New AIS Codes for Affected Products
In data element 2/03 of the Automated Import System (AIS) import declaration, declarants will use the relevant codes to ensure compliance. Here are some of the codes and their meanings:
- L139 – Import authorisation by virtue of article 3g.7 of Council Regulation (EU) 833/2014 (Iron and Steel).
- Y824 – Evidence of the country of origin of the iron and steel inputs used for processing of the product in a third country (Iron and Steel).
- Y859 – Goods entered the territory of the customs union of the EU and presented to customs authorities before the entry into force or applicability date of the present sanction, whichever is latest (see Article 12e of Regulation (EU) No 833/2014) (Iron and Steel).
It’s crucial for businesses importing or dealing with iron and steel products to take these sanctions seriously. The failure to comply with these measures can lead to financial penalties and possible legal action.
As an importer, it’s essential to work closely with your suppliers ensure compliance with these new restrictions. Additionally, maintaining detailed records and collecting the required evidence of origin is a key part of this process.
While the sanctions may pose additional challenges for businesses involved in this industry, understanding and adhering to the regulations is vital to avoid potential issues down the line.
For further guidance, it’s advisable to stay updated on any additional information provided by the European Commission.
The new EU sanctions on Russian iron and steel imports have introduced additional requirements for importers. Understanding these sanctions and ensuring compliance will be crucial for businesses dealing with iron and steel products. By following the recommended steps, you can navigate these restrictions effectively and avoid potential penalties. Stay informed and work with your supply chain partners to ensure a smooth transition into this new regulatory landscape.
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