Sanctions AI in practice: Turkish coil, Russian slabs, one certificate

A compliance specialist at a Spanish company that buys hot-rolled coil from a mill in Türkiye runs the routine checks on a new contract. The company does not trade with Russia or Belarus and does not route anything through them. That is exactly why the questions are hard: the Russian element, if there is one, is inside the coil, not on the bill of lading.

Two tools carry the routine. News agent follows changes in EU trade and sanctions law and reports daily what changed. Sanctions AI checks a commodity code and a route against the EU restrictions and shows the legal act behind every answer. Neither makes the compliance decision. What follows is one morning with both, and the three questions it produced.

Case 1. The certificate the mill already issues

The news item reports that the Commission has adopted the implementing act on the evidence importers must provide to prove the country of "melt and pour" of steel products covered by the Steel Regulation. From 1 October 2026 importers must declare that country on the customs declaration and support it with a mill test certificate showing the country of melt and pour and the heat number; for one year, other documents may stand in where no certificate exists. The specialist reads one word more carefully: "melt". The Turkish mill rolls the coil; it does not melt the steel. It buys slabs. Where the slabs were melted is not a new question - the sanctions regulation has required evidence of the origin of the inputs since 30 September 2023, and the supplier has answered it every year in a long-term declaration kept in the file. What is new is where the answer goes: from 1 October it is a data element on the customs declaration, supported by a certificate, and without it the coil is not released, whatever its origin.

The link below the item leads to the Commission's news of 31 August; the specialist then reads the CCRM article on the new rule, published the day the act was: Implementing Regulation (EU) 2026/1963, applicable from 1 October 2026, gives the evidence rules under Article 4 of the Steel Regulation (EU) 2026/1384. Hot-rolled coil of 7208 10 00 is in Annex I to that regulation. Without evidence of the country of melt and pour and the heat number, the import is rejected. The article makes one more point: the mill test certificate is the document importers already supply under the Russia sanctions, for a different purpose.

The specialist takes the supplier's declaration out of the file. It says: slabs of Russian origin, CN 7207 12 10, bought before the mill switched suppliers. The declaration was accepted last year; the specialist now puts the same facts, as stated, to Sanctions AI to see what they mean under both rules.

The answer has three parts, and the specialist needs all three. No prohibition applies today. The prohibition in Article 3g(1), point (d), of Regulation 833/2014 - Annex XVII products processed in a third country from Russian inputs - applies to inputs of 7207 12 10 only from 1 October 2028; the date comes from the second sentence of the provision, which the answer links. And at importation the company must provide evidence of the country of origin of the inputs, TARIC document code Y824, because Türkiye is not one of the partner countries in Annex XXXVI for which the evidence is waived. The answer adds what the Commission's FAQ says for this input code: until 2028, the mill test certificate may show Russia as the country of melting.

The specialist now reads the two rules together. The sanctions regulation asks for evidence of where the inputs were melted, to see whether they are Russian; a supplier's declaration has served, and the Commission's FAQ accepts it. From 1 October 2026 the Steel Regulation asks for the same fact, whatever the country, names the mill test certificate as the evidence, allows the other documents only until 30 September 2027, and refuses release without it. One fact, and from October one document, answers both. The certificate the Turkish mill issues today shows its own heat number and nothing about the slab. The specialist writes to the mill: from the next consignment, the certificate must show the country of melting of the slab and the heat number - not because the sanctions rule changed, but because the steel rule now needs the same fact on the declaration and enforces it by refusing release.

Case 2. One digit in the slab code

The mill's reply comes with a correction. Part of the stock was not 7207 12 10. It was 7207 11 - slabs of square cross-section, a different subheading of the same heading. The specialist runs the same question with one digit changed.

Same coil, same mill, same country, same route - and the answer flips. For inputs of 7207 11 the deferral ended on 1 April 2024; coil rolled from those slabs has been prohibited from import since then. The answer lists the three derogations - divestment and wind-down, goods already presented to customs before the prohibition, civil nuclear purposes - none of which fits a trading company's stock.

The specialist records the split: coil from the 7207 12 10 slabs can be imported with the evidence; coil from the 7207 11 slabs cannot. The certificate decides which is which, heat by heat. That is the practical content of "heat number" in the new rule: it is the line that ties a certificate to a coil. The supplier is asked to separate the stock by heat and to certify each. A specialist who had read only the headline - "Russian slabs, Turkish coil" - would have refused both lots or accepted both. The code and the date, read from the provision, allow neither shortcut.

Case 3. The alternative offer

The mill offers a way round the delay: it holds Russian slabs of 7207 12 10 in a Turkish port, unprocessed, and can ship them to Spain for the company to have rolled locally. Nothing on that route touches Russia. The specialist asks the tool.

The route does not help. Slabs of Russian origin are prohibited under Article 3g(1), point (a), wherever they ship from; a Turkish port changes nothing. The tool then does two things a good tool should do. It names the exception - the annual quota in Article 3g(4), 2,998,324 tonnes for the period ending 30 September 2026 - and it says what it cannot know: whether any of that volume is left.

The specialist opens the quota consultation. Order number 09.8258 is the quota for 7207 12 10. The 2025-2026 volume was used up on 27 April 2026, five days after the quota became critical. The balance is zero. The next volume, 2,623,534 tonnes, opens on 1 October 2026 - the same day the melt and pour rule starts - and at the rate the last one ran, it will not last the year. The offer is declined, with the quota page in the file as the reason.

What one morning teaches

Before relying on any tool for a check like this, a professional should be able to answer three questions about it: 

1. what was it built to answer, 

2. does it show its sources, and 

3. does it say what it cannot know. 

One morning gives the answers. News agent was built to report what changed in the law; it named the implementing act, summarised it and linked the Commission's notice. Sanctions AI was built to say which provision restricts a code on a route and under which conditions; it named point (d) and its date, the evidence code in its TARIC wording, the quota and its period - and where it could not know the balance, it said so.

What it left to the specialist is the part that matters. The origin of the coil was stated in the question, not decided by the tool. The slab code came from the supplier, heat by heat, and the answer changed with it. The quota balance came from the Commission's own page. The decision - which lots to import, which offer to decline, what the mill must certify from October - was the specialist's, made on evidence the tool had found in seconds and the specialist could check in minutes.

Two rules, one certificate. The sanctions regulation has asked for evidence of where the inputs were melted since 30 September 2023. The Steel Regulation asks for the country of melt and pour from 1 October 2026. A mill that shows the country of melting and the heat number on one document satisfies both. A mill that shows neither will have its coil stopped at the border, whatever the sanctions answer.

One more line from the Commission's notice belongs in the file. The quotas and the 50% duty apply to all origins except the EEA countries, and those countries, the Commission adds, "remain subject to melt and pour traceability requirements". The evidence rule reaches further than the quota rule. The sanctions regulation draws its line differently: coil from Switzerland or Norway needs no evidence of the origin of its inputs, because both are partner countries under Annex XXXVI, and the declaration carries code Y878 instead of Y824; from 1 October it needs the melt and pour certificate like coil from anywhere else. Two laws, two lists of countries, one document.

Sanctions AI and News agent are available at customsclear.net with a 14-day free trial.