New sanction measures against Russia impact imports of iron and steel products processed in third countries

Posted by Marcel van Leeuwen on October 03, 2023 · 5 mins read

From September 30, 2023, the EU is introducing new restrictive measures against Russia. These include all finished and semi-finished steel and aluminum products imported into the EU, for which the certificate of origin of the goods will no longer be sufficient. The importer will also have to provide a Mill Test Certificate (MTC).

According to Council Decision (CFSP) 2022/2478 of December 16, 2022, it shall be prohibited to import or purchase, as from September 30, 2023, directly or indirectly, iron and steel products as listed in Annex XVII when processed in a third country incorporating iron and steel products originating in Russia as listed in Annex XVII of Regulation (EU) No 833/2014 (see links to the texts mentioned at the end of the article).


The role of the MTC is to improve the transparency and traceability of products and their origins. There is no standard model certificate to be supplied, but the factory test report must contain the following mandatory information:

For semi-finished products :

The name of the plant where production took place, the name of the country corresponding to the casting number (foundry country), and the product’s CN code (six-digit code). For finished products (contained in one or more TCMs): The name of the country corresponding to the casting number (foundry country), together with the product’s CN code (six-digit code). The name of the country and the name of the facility where the following treatments or operations are carried out, if applicable:

  • Hot rolling
  • Cold rolling
  • Hot-dip metal coating
  • Electrolytic metal coating
  • Organic coating
  • Welding
  • Permeabilization/Extrusion
  • Stretching/Stacking
  • ERW/SAW/HFI/Laser welding This measure will be included in RITA (customs administration software) from September 30, 2023, when import controls will begin.


For products affected by these new restrictions, three codes can be entered on the customs declaration:

  • Code L139: Import authorization under Article 3g(7) of Council Regulation EU No. 833/2014: “ By way of derogation from paragraph 1, the competent authorities may authorise the purchase, import or transfer of the goods listed in Annex XVII, under such conditions as they deem appropriate, after having determined that this is necessary for the establishment, operation, maintenance, fuel supply and retreatment and safety of civil nuclear capabilities, and the continuation of design, construction and commissioning required for the completion of civil nuclear facilities, the supply of precursor material for the production of medical radioisotopes and similar medical applications, or critical technology for environmental radiation monitoring, as well as for civil nuclear cooperation, in particular in the field of research and development. “
  • Code Y824: Goods other than those listed in Annex XVII attached. Please note the use of certificate code Y824: if the imported steel products do not contain Russian steel products, certificate code Y824 must be entered in box 44 of the customs declaration. This certificate attests that, as the importer, the goods comply with the measures imposed and that the importer has the necessary proof to this effect.
  • Code Y859: Goods located in the European customs territory and presented to the customs authorities before the entry into force or the date of applicability of these sanctions, whichever is later (see Article 12e of Regulation (EU) No. 833/2014). REMINDER

It is forbidden:

  • a to import into the Union, directly or indirectly, the steel products listed in Annex XVII (attached) if they originate in Russia; have been exported from Russia
  • b purchase, directly or indirectly, the steel products listed in Annex XVII if these are located in Russia or originate from Russia
  • c transport the steel products listed in Annex XVII if they originate in Russia or are exported from Russia to any other country
  • d to provide, directly or indirectly, technical assistance, brokerage services, financing or financial assistance, including financial derivatives, as well as insurance and reinsurance products, in connection with the prohibitions set out in points a), b) and c) Council Regulation (EU) No 833/2014 - Article 3g(1) (Council Regulation (EC) No 2022/428)

The sanctions measures against Russia and the guidelines derived from them are subject to constant change. All other measures and obligations applicable to imports of steel products continue to apply.

Website of European Union:

  • Council Regulation (EU) No 833/2014 of July 31, 2014 concerning restrictive measures in response to destabilizing Russian actions in Ukraine and consolidated text until June 24, 2023 with list of products concerned Website of European Council :
  • Sanctions adopted following Russia’s military aggression against Ukraine

Marcel van Leeuwen

Marcel van Leeuwen was there from day 1 – he experienced all the challenges that Brexit brought and took all the colleagues by the hand in the joint efforts that were made. Marcel also has a long number of Years of experience especially in the Fresh Produce sector as declarant. First at Amsterdam Airport, later with a Transport Organisation and the last 4 Years with LBP Rotterdam BV as senior declarant. At RCS Marcel is the Operations Manager managing the day-to-day business.

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