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Russia Update: Iron and Steel products – new restrictions

The EU prohibits the import or purchase in the Union of products processed in a third country using iron and steel inputs originating in Russia.
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A.P. Moller – Maersk has released a customer advisory, in which, it says the company is closely following the ever-evolving situation of new sanctions against Russia and the regular adjustments that are being made to the list of restrictions.

Article 3g(1)(d), of the 11th package that the EU adopted “concerning restrictive measures in view of Russia’s actions destabilizing the situation in Ukraine” [EU regulation 2023/1214 amending regulation 833/2014] prohibits the import or purchase in the Union of products processed in a third country using iron and steel inputs originating in Russia. This prohibition can be found in Council Regulation (EU) No 833/2014 Article 3g 1(d) and the latest amendment Council Regulation (EU) 2023/1214.

As of September 30, 2023; this prohibition is in place and all customers are now obliged to provide evidence that the inputs used in the affected iron and steel products to be imported into the Union, are of non-Russian origin, in compliance with EU regulation. “We strongly encourage all customers with cargo that involves the affected steel and iron products to make sure that you have the required documentation available. If the required documentation is not available it could impact the entry of such items into the Union, please be aware that this could lead to delays, customs holds and/or possible enforcement against the customer for breach of sanctions. A.P. Moller – Maersk is at no time liable for compiling the documentation from the customer or to providing the required documentation to the authorities, this obligations rests with the customers.”

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