Compliance With New EU Steel Import Requirements Will Be 'Challenging,' Law Firm Says
A new set of overlooked EU import restrictions on iron and steel products with links to Russia could be a heavy compliance lift for certain importers, Baker McKenzie said in a July 6 client alert. The new restrictions, outlined in the EU’s most recent Russia sanctions package (see 2306230013), haven’t gotten the “attention they deserve,” the firm said, adding that they will force certain “economic operators” to prove the goods they’re importing “do not contain any Russia-originating sanctioned iron or steel item.”
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“Collecting such information is not only time-consuming but also very challenging,” the firm said, warning that failures to comply could lead to “major delays affecting your supply chain as well as potential litigation started by the Authorities in the countries of import.” Baker McKenzie noted the restrictions could affect importers in the building and infrastructure, mechanical equipment, automotive, transport electrical equipment and domestic appliances industries, all of which rely in some way on steel. Importers in those sectors “should act with extreme caution as there is a high risk that they may currently be importing products incorporating Russia-originating sanctioned iron or steel items,” the firm said.
Baker McKenzie suggested importers review their import data to flag imports of products that may be affected, whatever their non-preferential origin; review the customs classification of the targeted items; prioritize reviews of those items; and work with suppliers to collect information about those items, including bills of materials. EU importers also should be prepared to take action, such as self reporting violations, reviewing existing contracts, asking for certifications or “drafting documents to prove the absence of sanctioned Russia-originating iron or steel items in the imported products.”