Updated: 2nd October 2023

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Introduction

In June 2023, the European Union (EU) introduced new sanctions targeting the import of iron and steel products from Russia. These measures respond to Russia’s actions impacting the situation in Ukraine.

For businesses importing or trading in iron and steel, understanding these sanctions is crucial to ensure compliance and avoid penalties. This guide breaks down the key points from eCustoms Notification 25/2023, Council Regulation (EU) 2023/1214, and explains how to navigate the new restrictions effectively.

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Understanding the Sanctions

The EU sanctions prohibit the import of iron and steel products that:

• Originate in Russia
• Are exported from Russia
• Are processed in a third country using Russian iron and steel inputs

Affected products are listed in Annex XVII of the Regulation, covering:

• Tariff headings 7206-7229 (Chapter 72)
• Full Chapter 73 of the Combined Nomenclature (CN) codes

Effective dates: September 30, 2023, for most products.

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Key Dates to Remember

• CN 7207 11: Prohibition from 1 April 2024
• CN 7207 12 10 & 7224 90: Prohibition from 1 October 2024

Importers should check product CN codes carefully to ensure compliance.

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Importers’ Obligations

Under Article 3g(1)(d) of the Regulation, EU importers must:

• Provide evidence of the country of origin of iron and steel inputs used in third-country processing
• Ensure documentation is available for customs inspections
• Upload supporting documents during AIS import declarations to prevent delays

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Acceptable Documentation

Evidence of origin can include:

• Mill test certificates
• Invoices and delivery notes
• Quality certificates
• Long-term supplier declarations
• Production or calculation documents
• Customs documents from prior processing
• Business correspondence
• Manufacturer declarations
• Exclusion clauses in purchase contracts

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New AIS Codes for Affected Products

When lodging an import declaration in AIS, use the relevant codes in data element 2/03:

CodeMeaningL139Import authorisation under Article 3g.7 of Council Regulation (EU) 833/2014 (Iron and Steel)Y824Evidence of country of origin of iron and steel inputs used for processing in a third countryY859Goods entered the EU and presented to customs before the sanction’s entry into force or applicability date

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Next Steps for Importers

1. Verify CN codes for all iron and steel products
2. Collect and maintain evidence of origin for third-country processed goods
3. Upload supporting documents in AIS during customs declaration
4. Work closely with suppliers to ensure compliance
5. Stay informed on updates from the European Commission and Revenue

Non-compliance may lead to financial penalties and legal action.

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Conclusion

The new EU sanctions on Russian iron and steel imports introduce additional obligations for EU importers. Understanding CN codes, maintaining proper documentation, and correctly lodging AIS declarations are essential steps to remain compliant.

By staying informed and coordinating with suppliers and customs brokers, businesses can navigate these regulations efficiently, avoid penalties, and ensure uninterrupted operations.

Review your iron and steel supply chains and consult a customs expert to ensure full compliance with the latest EU sanctions.