At the end of September, new sanctions were introduced on the import of Russian goods to the European Union. In particular, against finished steel products manufactured in other territories (e.g. Turkey, China) from raw materials of the steel category originating in Russia (e.g. primary form of pig iron or semi-finished products). The sanction applies to almost the entire assortment of such steels.

From September 30, 2023, the direct or indirect import or purchase of metal products will be prohibited if they are processed in third countries and contain raw materials originating from Russia. Again, the sanctions show us how important the product selection process is in this industry.

Thus, when importing into the EU, companies that place steel products on the EU market will have to prove to the customs authorities that the metal products do not contain raw materials of Russian origin. Customs authorities are likely to require evidence such as supplier declarations and complex calculations of non-preferential origin. A useful tool to simplify these formalities is to obtain mandatory information on origin (IOO) from the customs authority. Once received, such a customs-certified document unequivocally certifies the origin of the imported finished product and raw materials used, valid for 3 years, saving the importer from unwanted discussions with the customs authority and delays in the supply chain.

The European Commission has also provided for some exceptions to the aforementioned limitation. In the case of steel products processed in a third country containing steel originating in Russia classified under CN code 7207 11, this applies from 1 April 2024 and from 1 October 2024 for Russian steel classified under NC codes 7207 12 10 SI 7224 90.

Another important aspect is the situation with stocks of such steel products in the EU. Are these stocks subject to restrictions after September 30, 2023? At the moment it is understood that their export outside the EU remains an option that is not subject to restrictions, but the trade of stocks remaining on the EU market can cause serious problems of interpretation and it is recommended to confirm this in advance with the competent authorities, as sanctions for defaults can be extremely large

In conclusion, it is recommended that importers of steel products require suppliers to provide clear proof of the origin of the products supplied, indicating the origin of the steel used in production. Based on them, apply for mandatory origin information from the customs authority to facilitate the import process.

The article was signed by Mihai Petre, International Trade Director of EY Romania and Cosmin Dinke, International Trade Manager of EY Romania