New sanctions against imports in the EU of steel products originating or exported from Russia

On 6 October 2022, Regulation (EU) 833/2014 concerning restrictive measures in view of Russia's actions destabilizing the situation in Ukraine has been amended to expand the existing financial and economic restrictions. Among others, the new measures include:

(i) New import bans introduced on Russian origin steel products

The new Regulation further extends the import ban on semi-finished steel products that either originate in the Russian Federation or have been exported from it as well as for steel products manufactured in third countries (other than Russia) by using Russian origin steel.

Starting with 7 of October 2022, imports of steel products originating or located in Russia falling under CN codes 7207 11 and 7207 12 10 are allowed in the limit of certain quantities for which EU tariff quotas were opened.

Also, as of 30 September 2023 the EU will extend the ban not only to the import of Russian steel products but also to steel products from third countries, if they were made of Russian steel. More precisely, import or purchases of iron and steel products subject to restrictions (e.g. 7224, 7207,7206) when processed in a third country (say Turkey) by using iron or steel products originating in Russia will be restricted in the EU. For products processed in a third country falling under CN codes 7207 11 or 7207 12 10 this restriction applies as of 1 April 2024.

(ii) Other import bans on Russian products

Certain types of machinery and appliances, and certain chemical products, including cosmetics are now banned from import. Vehicles, textiles, footwear, leather, ceramics, and articles of stone are also banned.

(iii) New bans for export from EU to Russia

Additional export restrictions were introduced including banning the export of coal, including coking coal, specific electronic components (e.g. semiconductor devices, electronic integrated circuits, cameras), technical items used in the aviation sector, as well as certain chemicals.

How does the above influence the activity of your company?

The scope of applicable sanctions targeting Russia has again been extended and companies should ensure that their sanctions compliance programmes, policies, screening processes, products and business partners are updated to ensure that the newly enacted sanctions are appropriately addressed.

We further recommend to closely monitor the situation to ensure compliance with potential new restrictions which may be imposed.

The EY Team is available for further details on the above.