EU now requires Mill Test Certificates (MTC) to exclude Russia as the origin of iron and steel

Date: 21/11/2023
Author: Greater Manchester Chamber of Commerce
Company: Greater Manchester Chamber of Commerce

The Mill Test Certificate (MTC), also known as a Mill Certificate or Material Test Report (MTR), is an important document in the quality control process for materials, particularly in metalworking, construction, and manufacturing industries. Its main purpose is to provide essential insights into the properties and quality of a specific batch or lot of material. Typically used for metals like steel, the MTC plays a vital role in ensuring the integrity of materials essential for construction and engineering projects. 

From the 30th of September 2023, new EU and UK sanctions target specific iron and steel imports, focusing on goods processed in third countries with Russian iron and steel. Importers must declare compliance upon entry and provide evidence if customs checks. 

While the exact documentation is not explicitly specified, the European Commission suggests that an MTC from the supplier may suffice. Customs authorities may request additional evidence if doubt arises. For businesses navigating this situation, consider the following steps: 

  1. Contact Customs Authorities: Inquire about specific requirements and acceptable documentation as evidence of origin. 
  1. Prepare Documentation: Ensure you have necessary documents such as Mill test certificates, invoices, delivery notes, quality certificates, or other relevant records indicating the non-Russian origin of products. 
  1. Collaborate with Suppliers: Work closely with suppliers to make them aware of the requirements and ensure they can provide the necessary documentation. 

Alternative Documents as Evidence 

Apart from MTC, the following documents can also serve as suitable evidence: 

  • Invoices, Delivery notes, Long-term supplier declarations 
  • Quality certificates 
  • Calculation and manufacturing documents 
  • Customs documents from the exporting country 
  • Business correspondence 
  • Production descriptions 
  • Manufacturer's declarations or exclusion clauses in sales contracts indicating the non-Russian origin of basic products. 

Due to different interpretations on the side of customs, consider including specific details: 

For Semi-finished Products: 

  • Facility name where production took place. 
  • Country corresponding to the heat number (country of the melting pot) 
  • CN number (6-digit code) of the product 

For Finished Products: 

  • Country corresponding to the heat number (country of the melting pot) 
  • CN number (6-digit code) of the product 
  • Country and facility names where specific processing or operations occur. 

Are you exporting or thinking of exporting to Russia but unsure about whether your goods require a license or compliance? Are you in need of expert guidance in the mined field of export licenses? Do you need support in Country of Origin determination or Free Trade Agreement eligibility assessment? 

The Chamber offers a comprehensive array of export control and license services, both in Manchester and beyond, available for face-to-face or virtual consultations: 

  • In-house and Bespoke Export Control Compliance Training: We provide tailored training, whether in-house or virtually, covering topics ranging from general compliance to specific business processes and procedures. 
  • Export Control Audit: Our team conducts internal business audits to assess your Business Management System's compliance with export control regulations. This can be part of your annual BMS audit schedule or in preparation for an Export Control Joint Unit (ECJU) visit/audit. 
  • Export Control Managed Service: Acting as your trusted partner, we serve as the central point for all licensing activities, ensuring alignment with your internal business processes and export control regulations. 
  • Product Codification: We audit and codify your products against the UK Export Control List, ensuring accurate definitions and understanding of licensing requirements. This typically includes an initial site visit for a comprehensive product assessment. 
  • License Application: We act on your behalf to ensure timely and accurate license applications, ensuring a seamless export process. These services can often be conducted remotely, especially if a prior product codification visit has been completed. 
  • SPIRE Set up and Management: We facilitate the setup of an HMRC SPIRE Account on your behalf and, if needed, provide ongoing account management to ensure efficient license management through the HMRC system. This can be accomplished remotely, depending on your IT requirements. 
  • ECJU Visit Representation: We offer representation services during an ECJU Audit, typically recommended when one or more of the above services have been availed. 

For more detailed information on any of the services listed above or to discuss your specific requirements, please don't hesitate to contact our expert team at We're here to assist you in navigating the complexities of export control and licensing with confidence.