From 30 September 2023, Europe will impose import restrictions on steel products originating in Russia. From that date, if the steel products concerned are processed in a third country using steel raw materials originating in Russia, they will be prohibited from being imported or purchased, directly or indirectly, into the EU.

This means that steel and stainless steel products originating in Russia may not be imported into the EU, and products of other origins may not enter the EU via Russian transport routes.

To ensure enforcement of the ban, the embargo regulation obliges EU importers to provide evidence of the origin of steel products. This evidence must be presented at the time of import of the materials or on request by customs: that is, if the customer's product contains iron, metal or similar materials, the advance declaration submitted must also be accompanied by a mill test certificate (MTC). The HS codes concerned are those starting with 72 to 83.

Where an MTC document cannot be provided, or where European customs considers that the MTC document is insufficient to prove the country of origin of the steel material, the customs authorities may require other evidence, such as additional separate test certificates for different stages of product processing, or the following types of documents:

Invoices

Delivery notes

Quality certificates

Declarations from long-term suppliers

Cost accounting and production documents

Customs documents of the exporting country

Business correspondence

Production descriptions

Exclusion clauses in sales contracts

Declarations made by the manufacturer directly related to the goods concerned

Note: the MTC document and all the above evidence are intended to prove that the manufacturing process of the product, from steel raw material to finished article, has no connection with Russia. Not all of these documents are required (importers may use the documents listed above to supplement the MTC document, or use the MTC document to supplement the documents listed above), but the more complete the information contained in the evidence provided by the importer, the easier it is to convince customs that the steel products and their steel materials do not originate in Russia.