From 30 September 2023, European sanctions against a large proportion of Russian steel products came into force.

This means that neither steel nor stainless steel products originating in Russia may be imported into the EU. From this date, importers into the EU will also have to prove that their products do not contain Russian steel.

The fact that goods have been processed in the UK and acquired either preferential or non-preferential UK origin does not exempt goods from these sanctions. If they contain Russian steel or stainless steel they will be affected.

UK Government guidance can be found here which includes a list of HS codes considered in scope for these sanctions.

Traders should be prepared to have documentation available to demonstrate evidence of a good’s supply chain, which must be consistent with the prohibitions under the regulations.

Evidence requested to be provided through documentation could include:

• the country of origin of the iron and steel products processed in the third country (or third countries) after the fact.
• the date that the iron and steel product left its country of origin.
• the country(s) and facility(s) where processing has taken place.

An example of evidence may include, but is not limited to, a Mill Test Certificate (MTC), or Mill Test Certificates (MTCs) where the relevant information cannot be summarised in a single document.

BCC Lobbying

We are aware that these new sanctions are causing significant issues for UK traders and the British Chambers of Commerce have been lobbying various UK Government and EU bodies to clarify and simplify the process. William Bain, Head of Trade Policy, BCC, met with the DBT Minister Lord Minto last Monday and the DBT/FCDO Special Advisor Victoria Hewson and they said they would take the issue away for further consideration. It is an EU policy so the UK cannot directly influence its implementation, but it can be raised in the normal diplomatic channels and if it is affecting areas in the TCA through relevant TCA specialised committees.

William also contacted the EU Embassy about this they will notify DG Trade in the European Commission in Brussels this week about the escalation of sanctions compliance difficulties.

Examples from the network

For your Chamber to push this further with DG Trade we need examples of your customers in the EU. We would also like to get some of these stories on the press to aid the lobbying impact.

If you have examples, then we need you to set out what the direct impact of the changes are for you – how difficult is it to do what’s asked? What are the repercussions if you can’t, what does it mean for your trade links into Europe? Stats on number of forms, parts you must account for, resource you are having to use to do it. These are all things that bring the story alive and help journalists explain the issues.

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