Non-preferential origin and EU sanctions on Russia

In this short presentation, Christelle Dubouchet, Global Senior Legal Counsel at SITA, explains how EU sanctions against Russia intersect with the rules of non-preferential origin, focusing on the iron and steel sector.

Topics covered:

• Regulation (EU) No 833/2014 and the EU's restrictive measures against Russia
• How non-preferential origin rules interact with the import ban on Russian-origin iron and steel
• Why the prohibition can still apply after substantial processing in a third country
• The two cumulative conditions that trigger the import prohibition (Annex-listed product and incorporation of Russian-origin material)
• Practical compliance steps: supplier certificates of non-preferential origin and supplier declarations of compliance (Article 3g)
• What evidence customs authorities are asking importing companies to provide
• Risks of inaccurate declarations: fines, penalties, seizure of goods, and reputational/legal exposure
• The evolving and expanding scope of EU sanctions packages against Russia

For a broader overview of the topic, please watch the full recording. The slides are available in the Resources section.

Please note that this summary was generated using AI, based on the recording and available slides.