The recent EU sanctions against Russia, the 11th package of measures, have far-reaching implications for companies involved in the import of iron and steel. These sanctions apply not only to goods coming directly from Russia, but also to goods processed with Russian raw materials in third countries.
What does the sanctions package entail?
The first part of the 11th sanctions package came into effect on September 30, 2023. This new package makes the rules stricter on proving where iron and steel comes from when brought to the EU via other countries (such as India and China). The aim is to prevent sanctions from being circumvented. If you import something, you now have to be able to show with all kinds of papers that your products do not come (indirectly) from Russia.
Timeline for implementation
The sanctions will be introduced in phases based on CN import number (European HS code) and can be found in ANNEX XVII of the Council Regulation No 833/2014. For convenience, we now call this 'the sanctions list'.
| entry date | sanctioned steel/iron products |
30-09-2023 | All products in the groups:
except:
|
1-4-2024
| All products in the groups:
except:
|
1-10-2024 | All products in the groups:
|
Examples
The implications for businesses
Due to these stricter rules, companies must pay extra attention. Ordinary certificates such as the certificate of origin are no longer enough to prove that the products do not come from Russia. This can have major consequences for how you purchase products and can even cause legal problems if you do not comply with the new EU rules.
Case study: The impact of EU sanctions on a customer
To illustrate how complicated the new rules are, we will use one of our customers from the packaging industry as an example.
This customer was concerned that they were violating the new EU sanctions because they were purchasing steel products that may contain Russian iron or steel. After carefully checking their situation and doing due diligence, we discovered that their steel actually came from Europe. This meant they weren't breaking any rules. The story shows how important it is to do your homework well.
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Read moreConclusion
The new EU sanctions on importing iron and steel are quite complicated and can have a significant impact on your business. The bottom line is that you now have to pay extra attention to where your stuff comes from. If you don't, you could get into trouble. Therefore, make sure you know what is going on and adjust your working methods if necessary, so that you do not run any risks.
Disclaimer
Please note: This is a snapshot.
Developments regarding sanctions follow each other in rapid succession. The information below may be out of date. Therefore, always consult the customs and EU website yourself or consult a consultant.
Sources:
- https://finance.ec.europa.eu/system/files/2023-10/faqs-sanctions-russia-listed-goods_en.pdf
- https://ec.europa.eu/taxation_customs/dds2/taric/taric_consultation.jsp?Lang=nl
- https://eur-lex.europa.eu/legal-content/NL/TXT/?uri=celex%3A32014R0833
All consulted on October 31, 2023
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