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EU trade sanctions against Russia

Answers to the most pressing questions on the latest restrictions

The EU has introduced a ban on the import or purchase of iron and steel products containing iron or steel inputs originating in Russia and processed in other, ‘third’ countries.

The EU and UK first banned the imports of certain iron and steel products from Russia in March/April 2022. We've compiled a FAQs to answer the most pressing questions on the latest restrictions.

What is the impact of these sanctions?

The EU regulations require importers to provide evidence of the country of origin for iron and steel inputs used in the processing of products in third countries. This requirement ensures that no Russian-origin materials are incorporated into the final products imported into the EU market.

The two main HS tariff chapters affected are:

72 – Iron and steel.

73 – Articles of iron and steel.

If the imported iron and steel products do not contain Russian steel products, code “Y824” should be entered in box 44.2 of the customs declaration. If the products do contain Russian steel products, importation is prohibited.

If the importer fails to present sufficient documentation from a customs authority perspective, the import will be rejected.

What you need to know about the sanctions

The EU regulations do not explicitly specify the exact documentation required to prove which country the iron and steel originated from. However, the European Commission has issued guidance that suggests a mill test certificate (MTC) may suffice to establish non-Russian origin.

In addition to the proposed mill test certificates, national competent authorities might determine the following documentation to prove evidence of the country of origin, restricting import of iron and steel products originating from Russia:

Invoices
Product descriptions
Quality certificates
Supplier declarations
Calculation and production documents
Customs documents of the exporting country
Business correspondence
Production descriptions
Declarations of the manufacturer or exclusion clauses in purchase contracts

For semi-finished products:

The name of the facility where production took place
The name of the country corresponding to the heat number (country of the ladle of melting)
Classification of the product’s subheading level (six-digit HS code)

For finished products:

Name of the country and facility corresponding to the heat number (country of the ladle of melting)
Classification of the product’s subheading level (six-digit HS code)
When relevant, the name of the country and facility where the following processing or operations were performed:
- Hot-rolling
- Cold-rolling
- Hot-dipped metallic coating
- Electrolytic metal coating
- Organic coating
- Welding
- Piercing/extruding
- Drawing/pilgering
- ERW/SAW/HFI/laser welding

The extent of documentation regarding what customs authorities expect may vary within the EU member states. Importers therefore should familiarise themselves with the new trade sanctions and contact local customs authorities, as well as Kuehne+Nagel, to apply domestic customs provisions.

Useful links:

Consolidated version of the frequently asked questions concerning sanctions adopted following Russia’s military aggression against Ukraine and Belarus' involvement in it – see page 170 ff.

EU trade sanctions against Russia

Answers to the most pressing questions on the latest restrictions

What is the impact of these sanctions?

What you need to know about the sanctions

What you need to know about the sanctions

What information must mill test certificates (MTC) contain?

For semi-finished products:

For finished products:

What should importers do?

Useful links: