The European Union has implemented a new import restriction affecting steel products that, although processed in a third country, incorporate materials or components originating in Russia. This measure is part of the restrictions motivated by the conflict between Russia and Ukraine, which are set out in Council Regulation (EU) No 833/2014.

The restriction is intended to ensure that products imported into the European Union have no link to Russia, either because they are manufactured or processed in Russia or because they include inputs of Russian origin. To justify that the products are not of Russian origin and have not been processed in Russia, importers can provide several types of evidence:

• Mill Test Certificate/material test report (MTC): The importer can request a MTC (Mill Test Certificate) from the supplier, which shows the origin of the goods that make up the product.
• Signed and sealed statement: Importers can submit a signed and stamped statement affirming that the goods are not of Russian origin, have not been processed in Russia and do not contain Russian inputs. The statement must include the ban on importing or purchasing Russian or Belarusian iron and steel products as of September 30, 2023.
• Certificate of origin: A certificate of origin certifying that the goods do not come from Russia and have not been processed in that country can be presented.
• Invoice caption: A caption can be included on the purchase invoice clearly stating that the goods are not of Russian origin, have not been processed in Russia and do not contain Russian inputs, and specifying their origin.

Prove the origin with an MTC

The European Commission has not specified particular evidence among those mentioned above and, for the time being, it is possible to use various forms of justification for the goods imported. However, the most reliable way to prove origin is through the MTC, which must include specific information depending on the product type, and whether it is semi-finished or finished.

Semi-finished product:

Name of production facility
Country Name
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Finished product:

Name of production facility and country
Name of country where processing operations have taken place
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This new measure is aimed at demonstrating that goods imported into the EU have no links to Russia. It is expected that the European Commission and the customs department will provide further clarification on the evidence to be presented in the future.

This restriction within the regulation is part of a wider context of restrictive measures taken by the EU in response to the Russian invasion of Ukraine. These measures are aimed at sanctioning Russia’s actions affecting the territorial integrity, sovereignty, and independence of Ukraine, and promoting a peaceful resolution of the crisis.