Following the Russian invasion of Ukraine, the European Union defined various sanctions against Russia, including a ban on the import or purchase, directly or indirectly, of steel products subjected to processing in a third country but which incorporate products steelworkers, originating in Russia.

To guarantee the effectiveness of this sanction, it is up to the competent Customs Authorities to define the adequate control tools and obligations incumbent on importers.

With the Notice dated 6 October 2023, the Customs Agency intervened to provide some specifications regarding the type of documentation to be collected to prove the legitimacy of imports.

The following are therefore considered valid pieces of evidence during customs clearance:

  • Mill test certificate (MTC): where it contains all the necessary information elements, it represents one of the means of proof considered admissible and it is not possible to provide a standardized model;
  • other means of proof: the origin of the production factors can also be established with others, such as a declaration from the exporter or producer who, certifying that he has carried out adequate checks, declares that the product does not contain steel or iron originating in Russia, or by the use of additional evidence or a combination thereof such as invoices, delivery notes, supplier’s declarations, commercial correspondence, production descriptions, quality certificates and clauses in purchase orders or executed contracts, provided that they include information on the origin of the production factors used.

The Customs Agency, in case of doubt, may request further information and evidence from the importer. In the Notice, it is clarified that importers are held legally responsible for what they declare and consequently for the correctness and consistency of the declarations produced by their suppliers.

The complete text of the Notice is available on the Customs Agency website at this link