On March 22nd, the European Commission proposed a regulation aimed at modifying the common customs tariff.

The objective of this proposal is to increase the customs duties applicable to the import of cereals, oilseeds and derived products currently classified in chapters 10, 12, 14, 15, and 23 of the Combined Nomenclature (CN), originating in or imported from the Russian Federation or the Republic of Belarus.

In almost all cases, tariffs on Russian and Belarusian exports to the EU would rise either to €95 per tonne or to an ad valorem customs duty of 50%, depending on the product. The affected products originating from Russia and Belarus will also be excluded from any tariff quotas.

The increased customs duties do not apply to importers of products that are neither of origin nor exported from the Russian Federation or the Republic of Belarus. However, importers of such products​ are also required to exercise increased vigilance (see below).

At present, this proposal is pending approval from the Council of the European Union.

Possible solutions when importing these products:

1. Processing within the EU: If you import these products for processing and then re-export the processed products, payment of customs duties can be entirely or partially avoided. This requires a customs authorization (inward processing), which is issued free of charge by the customs authorities.
2. Storage in a customs warehouse or temporary storage: Products can be stored in approved spaces without paying customs duties, allowing you time to wait for optimal market conditions. Simple transit through the EU is not affected.

Caution when dealing with suppliers in other countries:

If you are considering approaching suppliers in countries other than Russia and Belarus, if you are contacted by such operators, or if you are already trading with such suppliers, it is crucial that you rigorously ensure and take all necessary measures to determine the correct economic origin of the goods to avoid any tax evasion. This is especially important when ordering from countries that have strong economic ties with Russia and Belarus, such as Armenia, Kazakhstan, Kyrgyzstan, Moldova, Uzbekistan, Mongolia, Serbia, China, and India.

In the case of tax evasion, the importer may be held responsible by the customs authorities. An example of this is when it is discovered that the goods have a different origin than declared, resulting in too low or uncollected customs duties at the time of declaration.

We recommend taking proactive steps and appropriate measures to optimize your import activities if necessary.

We remain at your disposal for any further clarification you may require.