New EU sanctions package: Requirement to provide evidence on iron and steel imports

Under the EU's 11th sanctions package, a documentary evidence requirement came into force on September 30, 2023 for iron and steel imports if they originate in Russia or are exported from Russia.


Since the fourth EU sanctions package (March 15, 2022), there has already been a ban on the purchase and import of certain steel and iron products if they originate in Russia or have been exported there. The now 11th sanctions package brings this proof requirement for imports from all third countries.

Specifically, this means that since September 30, 2023, at the time of importation of certain iron and steel goods (listed by Lexparency), proof of the country of origin of these goods used for processing the product in the third country must be provided by logistics customers.

In addition to the Mill Test Certificates (MTC), following documents can also serve as suitable evidence:

  • invoices
  • delivery bills
  • quality certificates
  • long-term supplier declarations
  • calculation and manufacturing documents
  • customs documents from the exporting country
  • business correspondence
  • production descriptions
  • manufacturer's declarations or exclusion clauses in sales contracts indicating the non-Russian origin of the basic products.

Due to different interpretations on side of customs administration regarding the content of the alternatives to the MTC certificates, we recommend that the attached mentioned alternative documents include the following points.

For semi-finished products:

  • the name of the facility where production took place
  • the name of the country corresponding to the heat number (country of the melting pot) 
  • the CN number (6-digit code) of the product

For finished products:

  • the name of the country corresponding to the heat number (country of the melting pot) 
  • the CN number (6-digit code) of the product
  • the name of the country and facility where the following processing or operations, if any, are performed: hot rolling, cold rolling, metallic coating by hot dipping, electrolytic metal coating, organic coating, welding, penetration/extrusion, drawing/piling and ERW/SAW/HFI/laser welding

If you have any questions or are unclear about the EU's 11th sanctions package and the corresponding impact on your supply chains, please contact your usual Jet-Speed contact.