Following the Russia invasion of Ukraine, the European Commission has restricted imports of steel products from third countries for goods incorporating products of Russian origin.
As of 30 September 2023, the import declaration must indicate whether the products to be imported (classified under commodity codes 7206 up to and including 7229 and 7301 up to and including 7326) contain originating Russia. This is laid down by the European Commission in Article 3g, paragraph 1 letter d of EU Regulation 833/2014 .
This origin must be proven by the importer in collaboration with the producer by means of a MTC document (Mill Test Certificate) or other document accepted by the Finnish Customs. The presentation of a MTC document is a requirement within the import declaration process and must contain at least the following information :
- For semi-finished products (not fully finished product), a MTC must be added that shows at least:
- The name of the production facility;
- The name of the country associated with the ‘heat number’ (country of the ladle of melting);
- Classification (commodity code) of the product (6-digit).
- For complete end products, a MTC must be added that shows at least:
- The name of the production facility;
- The name of the country associated with the ‘heat number'(country of the ladle of melting);
- Classification (commodity code) of the product (6-digit);
- The name of the country and the name of the facility where the following operations or processing operations are carried out, as relevant:
- Hot-rolling
- Cold- rolling
- Hot dipped metallic coating
- Electrolytic metal coating
- Organic coating
- Welding
- Piercing/extruding
- Drawing/pilgering
- ERW/SAW/HFI/Laser welding
Due to these changes, Customs Support will take measures in order to ensure the compliance of customs clearances relating to steel and iron products. This will cause some changes in the clearing requirements where we would need your collaboration and consideration so that we can ensure a fluent clearance process for all compliant goods:
- If there is an origin Russia, Customs Support is entitled to refuse the import declaration as it is not allowed to import these goods to the EU.
- Customs Support must receive a copy of the MTC document with each order for entry.
- In addition Customs Support has drawn up a letter of indemnity (LOI). This LOI must cover each assignment related to these restriction measures.
- Preferential documents (EUR.1, statement of origin) or non-preferential documents (COO) are not sufficient to prove origin under this measure. Despite the fact that the origin meets the requirements of the (non) preferential documents, the products can always contain a percentage or parts from Russia.
Please note that the customs authorities have the right, in case of any doubts, to request additional supporting documents which could further prove the origin.
If you have any questions or doubts, please feel free to reach out to us. We thank you for your collaboration and understanding in this matter.
