Russian Steel Sanctions

From 30 September 2023, European sanctions against a large proportion of Russian steel products came into force. This means that neither steel nor stainless steel products originating in Russia may be imported into the EU. From this date, importers into the EU will also have to prove that their products do not contain Russian steel.

The fact that goods have been processed in the UK and acquired either preferential or non-preferential UK origin does not exempt goods from these sanctions. If they contain Russian steel or stainless steel thy will be affected.

UK Government guidance can be found here which includes a list of HS codes considered in scope for these sanctions: https://www.gov.uk/government/publications/notice-to-importers-2953-russia-import-sanctions/guidance-on-third-country-processed-iron-and-steel-measures#:~:text=The%20prohibition%20on%20the%20import,goods%20covered%20by%20the%20measure.

Traders should be prepared to have documentation available to demonstrate evidence of a good’s supply chain, which must be consistent with the prohibitions under the regulations.

Evidence requested to be provided through documentation 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.

BCC Lobbying

The BCC is aware that these new sanctions are causing significant issues for UK traders and the BCC have been lobbying various UK Government and EU bodies to clarify and simplify the process.  It is an EU policy so the UK cannot directly influence its implementation, but it can be raised in the normal diplomatic channels and if it is affecting areas in the TCA through relevant TCA specialised committees. 

If you and/or your customers in the EU are affected by these sanctions, please get in touch with Lorraine Holt, International Trade Manager.