Extension of import ban on iron and steel from Russia

From Q4 2023, (products of) iron and steel may only be imported into the European Union (EU) if these goods do not contain Russian commodities. As an importer, you can prove this by keeping certain documents in your records. The Mill Test Certificate (MTC) is the most important of these.
As an importer, you are responsible for the information provided to Customs via the MTC. In case of doubt, they can ask for additional evidence.
An exception applies to goods produced before 24 June 2023.

What should be in the MTC?

The MTC must contain at least the following information:

For semi-finished goods

  • the name of the facility where production took place
  • the name of the country corresponding to the heat number (the country where the operation took place)
  • the CN number (6-digit code) of the product

For finished products

  • the name of the country corresponding to the heat number (the country where the operation took place)
  • the CN number (6-digit code) of the product
  • the name of the country and facility where any of the following processing or operations are carried out: hot rolling, cold rolling, metallic coating by hot dipping, electrolytic metal coating, organic coating, welding, penetration/extrusion, drawing/piling and ERW/SAW/HFI/laser welding

Simply having a certificate of origin of the goods is therefore not enough.

Other records
You may not be able to show an MTC. Or maybe an MTC does not contain all the information we mentioned above. Therefore, you may use documents other than an MTC as evidence. For example:

  • invoices
  • delivery notes
  • quality certificates
  • long-term supplier declarations
  • cost accounting and production documents
  • customs documents from the exporting country
  • commercial correspondence
  • production descriptions
  • exclusion clauses in sales contracts
  • manufacturer’s declarations referring directly to the shipment in question (no general declarations)
  • We can request the documents after importation and carry out further investigation

You cannot (yet) use a certificate of non-preferential origin (CoO) as proof.

When making an import declaration, we must indicate whether or not the raw materials of the imported products originate in Russia. If this is not the case, a document code Y824 will suffice. So in any case, you should confirm to us whether the origin of the material is Russian or not because we do not have access to your records.
This could be done with a declaration signed and stamped by your supplier, for example:

… (name producer)… of these goods with HS code(s) 7326909890 declares that in this invoice number ………… no Russian
iron- or steel products or such products from Russia have been produced or used for the manufacturing of these products.
We declare that – in case of doubt- further proof can be delivered upon request of the importer, customs-agent or customs-authorities.
Signature + Stamp :

Furthermore, you should see to it yourself that you have requested documents and proof on file so that you can produce them in case of any customs inspection.
We advise you to ask your supplier for an MTC with every shipment containing HS codes from chapter 72 or 73.
If you do not get it, you can file other documents.

With every customs declaration containing metal raw materials, we must indicate whether or not these substances have Russian origin.
To avoid many administrative operations, it is also possible to issue us with a general declaration annually. With this, the importer (you) indicates to the declarant (us) that the goods do not contain raw materials of Russian origin unless otherwise indicated in the clearance instruction.
Bear in mind that during a subsequent inspection at your company it must be demonstrated that the imported goods indeed do not contain raw materials of Russian origin. This can be demonstrated as described above. The importer is responsible for this himself! Merzario has no obligations in this respect.


We hereby declare that the goods in our shipments, imported in 2024, do not contain raw materials of Russian origin. We therefore authorise Merzario B.V. to use the fictitious bescheid code Y824 in our customs declarations.

When goods do import with raw materials of Russian origin, we will clearly state this in our customs clearance instruction. If there is no customs clearance instruction, we will notify the Merzario customs department (douane@merzario.nl) prior to the customs declaration, stating the reference number.

Signature and company stamp

(signed by signatory)