The warning comes from the Confederation of British Metalforming (CBM), which is urging companies to explore the legislation, which requires evidence that iron and steel used to produce components in a third country outside the EU, including the UK, does not originate from Russia.
Material test certificates will be required to confirm the facility and location at which the material was originally melted and poured as well as for secondary steel processes.
CBM president Stephen Morley believes many firms will be unaware of this change to exporting and that it could cause products to be delayed at customs. In some instances, hold ups could trigger production stoppages in the automotive and aerospace sectors.
“It is important to recognise that the scope of the EU measures on iron and steel products extends far beyond primary and secondary steel products to encompass many finished goods, including fasteners and other industrial consumables. They will also cover many ‘retail’ products, such as stoves, cookers and kitchen and sanitary ware,” said Morley. “We have been warning our 200-strong membership body for more than a month now, working with them to ensure they are able to provide the required evidence at point of importation.”
He continued: “Effectively, it is a case of prepare for the worst-case scenario, while fervently hoping that EU authorities recognise that the stringency of compliance requirements will jeopardise the flow of UK to EU supply chains.”
Since alerting members to this issue, the CBM has been working with Crowe UK and its customs team to validate its assessment and to interrogate the recently released FAQ Guidance by The European Commission.
CBM said it is concerned that other associations and industrial membership bodies do not appear to have recognised the significance of the new sanctions.
Morley said: “There’s a lot of mixed messaging out there, with some suggestions that German Customs may take a more pragmatic view about what evidence is required, whilst the latest info from Belgium and France suggest a more stringent approach.
“It’s so confusing for bosses that are already struggling with the impact of increased admin and trying to grapple with extortionate inflationary pressures and energy prices. It’s one more spectre on the horizon that we could all do without.”
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