What does the eighth package of sanctions mean for the steel industry of the EU and the Russian Federation

As part of the fourth package of sanctions, the European Union banned the import of Russian steel products included in the system of import quotas (rolled steel and pipes) from April 1, 2022. The eighth package of sanctions expands previously introduced restrictions:

• firstly, the EU extended the ban not only to the import of Russian steel products, but also to steel products from third countries, if they were made of Russian steel;
• secondly, the European Commission expanded the list of codes subject to restrictions. Taking into account the eighth package of sanctions and previously introduced restrictions, the import of goods from group 72 «Ferrous metals» (with the exception of 7201 «Pig iron» and 7202 «Ferroalloys») and group 73 «Ferrous metals products» was banned. At the same time, if within the framework of the fourth package product codes were specified in detail (7217 10 10, 7228 50 61, etc.), then in the eighth package, the European Commission decided to duplicate them at a more generalized level (7217, 7228, etc.). Obviously, this way excludes possibility that part of the products at the level of individual subcodes is not included in the fourth package of sanctions.

New products that have come under the restrictions of the eighth package of EU sanctions

New restrictions on steel imports enter into force on September 30, 2023, with the exception of certain steel semi-finished products – billets and slabs. Import of billets (code 7207 11) is prohibited from April 1, 2024, and the import of slabs (code 7207 12 10) – from October 1, 2024. At the same time, quotas are introduced for the import of billets and slabs from the Russian Federation.

Quotas for the import of steel semi-finished products from Russia

Considering the amount of supplies, it will not be a big problem for European producers to refuse the import of products that do not belong to semi-finished products made of carbon steel. Thus, imports of stainless steel in ingots or other primary forms (7218), wire of stainless steel (7223), and cast iron pipes (7303) have historically been insignificant. Import of carbon steel in ingots (7206) fell sharply in 2022. In 2021, European producers imported significant volumes of alloy steel in ingots (7224) and wire of alloy steel (7229), however, based on statistics for 6 months of 2022, import volumes also decreased significantly.

Import of Russian steel products to the EU in 2021 and for 6 months of 2022

The situation with the import of steel semi-finished products is much more complicated. There are rolling mills in the EU (in particular, belonging to Russian companies), that work on imported semi-finished products. That’s why European rerollers came out first of all against the ban on the import of slabs from Russia. As it is seen from the eighth package of sanctions, their demands were heeded.

Import of steel semi-finished products from Russia to the EU in 2021 and for 6 months of 2022

In 6 months of 2022, billets (7207 11) and slabs (7207 12 10) accounted for 99.7% of steel semi-finished products’ imports to the EU. During this period, deliveries of billets from the Russian Federation to the European Union increased by 10.7% year-on-year, and slabs – by 20.8%. The increase in Russian imports became possible due to the absence of Ukrainian suppliers on the market, while problems of Ukrainian steel companies are mainly related to the actions of the Russian army.

The import of billets and slabs from Russia will continue until 2024 within large import quotas. Allowed monthly slab imports will be only 20% lower than actual average monthly imports in 2022. Quotas on billets provide for a gradual decrease in imports from Russia: in the first period of quotas’ validity – by 10.1% compared to the average monthly import in 2022, in the second period – by 37.1%, in the third period – by 64.1%. The European Commission believes that European producers will be able to quickly replace the billet from Russia with similar products from other countries.

Comparison of average monthly volumes of semi-finished products’ deliveries from the Russian Federation (thousand tons): 6 months of 2022 and the quotas proposed by the European Commission

Sanctions introduced by the European Commission do not create significant problems for European steel industry. Deliveries of critically important semi-finished products from Russia will continue for another two years. For other products, there is an opportunity to find alternative suppliers, especially as the volume of imports from Russia is already decreasing. In the future, several scenarios are possible depending on the situation in Ukraine and the actions of the European Commission:

1. The end of the war in Ukraine and the lifting of sanctions on Russian suppliers. In this case, deliveries of semi-finished products from Russia will continue, and other products will be able to return to the EU market. This is a very real scenario, since the introduction of bans has been postponed until 2023-2024.
2. The end of the war in Ukraine and the return of Ukrainian steel suppliers to the EU market. Ukrainian suppliers will be able to replace Russian supplies, and the volumes, that will be lacking, come from alternative sources. Russia is losing the EU market.
3. The full entry into force of sanctions in 2024 and the absence of Ukrainian suppliers on the EU market. European rerollers can again turn to the European Commission and ask for another delay to continue importing semi-finished products from Russia. The European Commission can make changes to previously adopted acts, so the option of prolonging the postponement cannot be ruled out. In addition, European rerollers will import semi-finished products from alternative suppliers. Perhaps, sanctions will be lifted from Iran until that time and Iranian producers will return to the European market. Turkey, China and other Asian countries will  intensify trade with the EU. It is possible that Russian products will also be supplied to the European market, bypassing sanctions.

Although the sanctions directly prohibit the import of steel products produced in third countries from Russian steel, the control mechanism is unclear (its potential effectiveness is questionable). In addition, Russia will be able to increase the export of pig iron, which is not subject to sanctions. That is, Russian pig iron will be able to be exported both to EU countries and to Turkey, China and other countries that will be able to supply products made from Russian pig iron to the EU.

Moreover, the growth of Russian pig iron exports is possible under any scenario. After the entry into force of the eighth package of sanctions, pig iron remains the only product that Russian steelmakers will be able to export without restrictions.