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Documentation requirements for the import of certain iron and steel products

From the 30th of September 2023, it is prohibited to import or buy several iron and steel products that have been processed in a third country and that contain Russian iron and steel, see the Ukraine regulations § 17e first paragraph letter d. These requirementsdo not apply to iron and steel products processed in a third country prior to the 30th of September 2023.

A third country is defined as a country that is neither Norway nor a member state of the EU, see the Ukraine regulations § 2 letter cc. 

The products covered by the ban are listed in Annex XVII of the Ukraine regulation. From the 30th of September, the ban applies to products containing other iron and steel materials than those covered by item number 72.07.1100, ex. 72.07.1200, 72.24.9010 and 72.24.9090. From 2024, the ban will cover several products. 

Goods that are released for free circulation within the EU, or for goods that are part of a finished product that is freely sold within the EU, are exempt from the import ban in § 17e. The ban does not apply to purchases and transfers in Norway. The Ministry of Foreign Affairs issued a Norwegian press release which is available here: Presisering om import av russiskjern og stål - 

On the 2nd of October 2023, a requirement for documentation of the country of origin was introduced, see the forskrift-om-endring-av-sanksjonsforskrift-ukraina.-11.-pakke.pdfregulation on amendment of the Ukraine regulation and the associated press release in Norwegian. This requirement means that importers must the country of origin for iron and steel input factors used in processing the product in a third country. Upon importation, the importer must be able to document that the goods covered by the import ban pursuant to §17e first paragraph letter d, cf. Appendix XVII, do not contain material of Russian origin. 

The importer/ the customs representative is obligedto document that the goods do not contain input materials of Russian origin. This documentation must be available at the time of declaration. If the goods do not contain Russian input materials listed in § 17e Annex XVII, the following must appear in section 44 of the declaration: "TXT: non-RU origin of the input goods. Approved documentation that describes the origin of the goods is: 

• MTC (Mill test certificate) 
• Invoice 
• Delivery note 
• Supplier declaration 
Production description 

Importers are free to choose any of the listed documents, provided it documents that the goods do not contain Russian input materials as mentioned in Appendix XVII. The importer must be able to provide sufficient documentation.  

For more information on MTC for semi-finished and finished products, see the European Commission’s consolidatedFAQ.see the faqs-sanctions-russia-consolidated_en_3.pdfEuropean Commission's answer to question 5 and 6.