Distinguished clients,
We inform you that on 09/30/2023, article 3 octies of R/EU 833/2014 L-229 (07-31-2014) came into force, which establishes the prohibition of importing or acquiring, directly or indirectly, steel products. listed in Annex XVII, when they are transformed into a third country incorporating steel products originating in Russia listed in that same Annex.
The art. 3 g contemplates the following exceptions regarding the date of application of the prohibitions:
- 7207.11: The ban will apply starting April 1, 2024.
- 7207.12.10 and 7224.90: The ban will apply starting October 1, 2024.
The aforementioned article establishes the obligation, for the EU importer, to provide evidence of the country of origin of the iron and steel inputs used in a third country for the transformation of steel products imported into the Union. Therefore, the measure affects any origin other than Russia.
The following documents may be considered sufficient proof of the country of origin of the iron or steel used as inputs:
- a) In the case of semi-finished products:
The factory test certificate (MTC) which establishes the name of the facility where production takes place, the name of the country corresponding to the thermal number (country of the melting ladle) together with the classification at subheading level ( six-digit code) of the product.
- b) In the case of finished products:
The factory test certificate (MTC) or factory test certificates (MTCs), if all relevant information cannot be summarized in a single MTC that includes:
- the name of the country and the name of the facility corresponding to the thermal number (melting ladle country) together with the classification at subheading level (six-digit code), and
- the name of the country and the name of the facility where the following processing operations are carried out, as applicable:
o Hot rolled
o Cold rolled
o Hot dip metal coating
o Electrolytic metal coating
o Organic coating
o Welding
o Drilling/extrusion
o Stuffing/Peeling
o ERW/SAW/HFI/Laser Welding
However, in relation to admissible evidence, there is no closed evidence. As indicated by the European Commission in the published frequently asked questions, the MTC can be considered sufficient evidence, but any other evidence from the country of origin that justifies that the merchandise is not affected by the ban can be admitted.
The importer will be responsible for the information provided in the MTC or MTCs and presented to the customs of the Member State of import as proof of the country of origin of the steel inputs used.
Any means of proof that proves that the inputs used in the manufacture of the manufactures will be valid, for example, an invoice certification that certifies that the origin of the inputs is NOT Russia.
For any additional questions, please consult our department. customs or you can also consult these links of interest: