Consolidated version on the implementation of Council Regulation No 833/2014 and Council Regulation No 269/2014 [Version of 18 July 2023]

The EC has published an updated consolidated version of its FAQs on the implementation of Council Regulation No 833/2014 and Council Regulation No 269/2014 in light of the ongoing conflict in Ukraine. The consolidated version includes FAQs concerning EU sanctions adopted following Russia’s military aggression against Ukraine.
Below we would like to present one new and one amended question in full, quote:
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Section D „TRADE AND CUSTOMS.“, topic 5 „IMPORT, PURCHASE AND TRANSFER OF LISTED GOODS“ (starting on page 159)
New Question 11 (p. 163) What do I need to know before I plan to import into the Union iron and steel products as listed in Annex XVII when processed in a third country?
Answer: Prohibition to import iron and steel products processed in a third country using Russian iron and steel inputs -evidence of the country of origin of the inputs
Article 3 g (d) prohibits the import or purchase in the Union of products processed in a third country using iron and steel inputs originating in Russia.
– Evidence of the country of origin
In order to ensure the implementation of the prohibition, the same Article establishes an obligation for the importer in the EU to provide evidence of the country of origin of the iron and steel inputs used in a third country for the processing of the iron and steel products imported in the Union.
The following documents may be considered as sufficient evidence of the country of origin of the iron or steel used as inputs:
a) In the case of semifinished products: The mill test certificate (MTC)
– establishing the name of the facility where the production is taking place, the name of the country corresponding to the heat number (country of the ladle of melting) together with the classification at subheading level (six digit code) of the product.
b) In the case of finished products
The mill test certificate (MTC) or mill test certificates (MTCs) – if all relevant information can’t be summarized in one single MTC:
– establishing the name of the country and the name of the facility corresponding to the heat number (country of the ladle of melting) together with the classification at subheading level (six digit code), and
– the name of the country and the name of the facility where the following processing operations are carried out, as relevant:
– Hot-rolling
– Cold-rolling
– Hot-dipped metallic coating
– Electrolytic metal coating
– Organic coating
– Welding
– Piercing/extruding
– Drawing/Pilgering
– ERW/SAW/HFI/Laser welding
The importer is responsible for the information provided in the MTC or MTCs and submitted to the customs of the MS of importation as evidence of the country of origin of the iron and steel inputs used.
The customs authorities may, in the event of reasonable doubt, require any additional evidence such as supplementary separate mill test certificates for the different transformation steps which the product has undergone. All MTCs should be coherent with one another. The importer should apply due diligence to ensure the accuracy of the information provided.
– Entry into application of the prohibition depending on the product
The prohibition to import or purchase iron and steel products processed in third countries using iron or steel originating in Russia enters into application at different moments depending on the inputs used, as follows:
– as of 1 April 2024 for products of Annex XVII containing products of CN code 7207 11,
– as of 1 October 2024 for products of Annex XVII containing products of CN codes 7207 12 10 or 7224 90,
– as of 30 September 2023 for products of Annex XVII containing products other than those of CN codes 7207 11, 7207 12 10 or 7224 90.
As products of CN codes 7207 11, 7207 12 10 and 7224 90 are semifinished products, this implies that as of 30 September and before 1 April 2024 for products using the inputs of CN code 7207 11 and before 1 October 2024 for products using the inputs of CN codes 7207 12 10 or 7224 90, in the MTC the Russian Federation may appear as the name of the country corresponding to the heat number (country of the ladle of melting). However, the Russian
Federation should not appear as the country where the other processing operations have been carried out (i.e. hot rolling, cold rolling, etc) in order to allow the import or purchase in the Union of the product.
After 1 April 2024 for products using inputs of CN code 7207 11 and after 1 October 2024 for products using inputs of CN codes 7207 12 10 or 7224 90, as well as from 30 September 2023 for products using all other iron or steel inputs of Annex XVII, in the MTC the Russian Federation should not appear as the name of the country corresponding to the heat number (country of the ladle of melting) and should not appear either as the country where the other processing operations have been carried out.
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Section G „SECTOR SPECIFIC QUESTIONS“, topic 1 „MEDIA“ (starting on page 229)
Amended Question 3 (p. 231) The targeted entities have Internet subdomains and also newly-created domains. Are EU operators obliged to avoid enabling, facilitating or otherwise contributing to access to all such subdomains and new domains?
Answer: The entity that registers a domain has control over the subdomains; if the domain is blocked, its subdomains should be blocked as well. The prohibition laid down in the Regulation also applies to newly created Internet domains that are in substance run or controlled by the targeted entities or used to circumvent the prohibition at issue. Indicative and non-exhaustive lists of domains and subdomains can be found in the websites of
some national regulators:
– NEW https://www.traficom.fi/sites/default/files/media/file/Muistio%20mediapakotteiden%20toteuttamisesta%20avoimen%20internetin%20asetuksen%20valossa_EN.pdf
– https://www.rtk.lt/lt/atviri-duomenys/ribojimai-susije-su-tarptautiniu-sankcijuigyvendinimu
– https://www.rtk.lt/uploads/documents/files/atviri-duomenys/neteisetos-veiklosvykdytojai/IP_adresu_sarasas.txt
– https://www.rtk.lt/lt/atviri-duomenys/neteisetos-veiklos-vykdytojai
– https://www.rtr.at/Paragraf_64_3a_AMD-G
– https://ttja.ee/ariklient
– https://www.teleindu.dk/brancheholdninger/blokeringer-pa-nettet/