EU/UK Prohibition on Imports of Russian Iron and Steel processed in a Third Country

The European Union (EU) is similarly introducing a prohibition on the direct or indirect import or purchase, from September 30, 2023, of iron and steel products listed in Annex XVII to Regulation (EC) 833/2014 when processed in a third country incorporating iron and steel products originating in Russia as listed in Annex XVII. Annex XVII similarly contains products with HTS / Combined Nomenclature (CN) codes falling within Chapters 72 and 73.

The UK sanctions came into force on September 30th, 2023. The EU restrictions rolls out in below three phases – depending on the specific classification code of the imported iron and steel products.

The following link contains the prohibited products:
The Russia (Sanctions) (EU Exit) Regulations 2019 (legislation.gov.uk)
EU Regulation (EC) 833/2014 Annex XVII

In the case of a product is being imported into the EU or UK, and the product is within the scope of the Russia Sanctions product list, regardless of the origin of the finished product, the importer must be able to demonstrate where the Iron or Steel raw product was from.

Importer Guidance – Demonstrating Supply Chain History

The importer must hold evidence that shows the product does not contain Russian origin Iron or Steel, this 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.

IMPORTANT: The EU have mandated under Article 3g 1. (d) of 833 that evidence must be held at the time of importation.

The EU’s restrictions phase into effect: 

• September 30th, 2023, for products of Annex XVII containing products other than those of CN codes 7207.11, 7207.12 10 or 7224.90. 
• April 1st, 2024, for products of Annex XVII containing products of CN code 7207.11. 
• October 1st, 2024, for products of Annex XVII containing products of CN codes 7207.1210 or 7224.90.

What does this mean for You?

Exporters/Importers please be prepared to include assurances that imports are not of Russian origin in contractual agreements. If there is a product that falls under one of the restricted codes, the Importers will require a letter or other written confirmation that the iron or steel originates from outside of the Russian Federation for the UK, but documented evidence must be held and produced for imports into the EU.

Any questions please reach out to Crane Global Trade Compliance Team: globaltradecompliance@craneww.com