EU Issues Guidance for Russia-Related Iron, Steel Trade Restrictions
The EU this week issued 11 new frequently asked questions to provide importers more guidance on its trade restrictions for iron and steel products made with Russian inputs. The FAQs provide more guidance on conducting due diligence on iron and steel products processed in third countries with inputs from Russia, whether the restrictions apply to temporary imports, country of origin documentation requirements.
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When importing certain covered iron and steel products that have been processed in a third country, EU companies must "provide evidence of the country of origin of the iron and steel inputs used" during the processing stage in the third country, the FAQs said. The guidance lists documents that may be "considered as sufficient evidence of the country of origin" for either semi-finished or finished iron or steel products, including mill test certificates. The EU importer is "responsible for the information provided in the MTC or MTCs and submitted to the customs authorities of the Member State of import as evidence of the country of origin of the iron and steel inputs used," the FAQs said.
In the "event of reasonable doubt," European customs authorities may require "additional evidence such as supplementary separate mill test certificates for the different transformation steps which the product has undergone," the guidance said. "All MTCs should be coherent with one another. The importer should apply due diligence to ensure the accuracy of the information provided."
Also, the MTC is only "an example" of a document "that can be regarded as sufficient evidence," but it's up to individual member states "to establish which other documentation can be considered as evidence" of the country of origin. These may include a declaration by the exporter or manufacturer "confirming that, after exercising due diligence, the imported product does not contain any Russian steel or iron." Other documents may be invoices, delivery notes, supplier declarations, business correspondence, production descriptions, quality certificates and clauses in purchase orders or contracts and more.