Export of Ukrainian metal structures to the EU: customs and certification requirements

Transformation of the Export Paradigm: Challenges and Strategic Imperatives

The Ukrainian metallurgical industry and the manufacturing sector of metal structures are in a state of deep structural transformation, driven by an unprecedented combination of macroeconomic, geopolitical, and regulatory factors. As of 2026, the industry operates under the simultaneous pressure of the consequences of military actions, logistical constraints, a shortage of qualified personnel, high energy prices, and the growth of steel imports into the domestic market. Under these conditions, reorienting towards export markets, primarily to the European Union countries, has become not just a development vector, but the only survival strategy for many manufacturers.

However, the European market for building materials has evolved from the traditional model of price competition to an extremely complex, strictly regulated ecosystem. Today, access to this market is determined not only by the cost of a ton of steel or aluminum, but by the manufacturer’s ability to integrate into the European regulatory and digital space. The modern paradigm requires Ukrainian enterprises to overcome multi-level non-tariff barriers, which are formed at the intersection of technical standardization (harmonized standards of the EN 1090 series and ISO 3834), customs digitalization (transit system NCTS Phase 5), unprecedented climate policy (CBAM mechanism) and radically updated legislation regarding construction products (Regulation CPR 2024/3110).

In-depth analysis of trends indicates that the existence of a free trade regime and zero customs rates is merely an illusion of market openness. The actual admission of each batch of steel beams, aluminum facade systems, or bridge sections depends on a flawless history of raw material origin, confirmed by an independent audit of welding quality, a digitized environmental footprint, and the ability to generate product lifecycle data. Manufacturers who continue to view export solely as a logistical task inevitably face cargo blockages at customs, reputational losses, and the inability to legally place products on the internal EU market. The ability to adapt to these requirements necessitates a complete restructuring of corporate governance, the implementation of new quality control systems, and significant investments in compliance.

Classification of Goods and the Architecture of Basic Customs Regulation

The foundation of any foreign economic operation is the error-free classification of goods, since the application of customs rates, non-tariff restrictions, and certification procedures depends entirely on it. Building metal structures and their parts are classified according to the Ukrainian Classification of Goods for Foreign Economic Activity (UKT ZED), which is fully harmonized with the European customs nomenclature. The key heading for this industry is 7308.

According to the classification methodology, heading 7308 covers structures of iron or steel and parts thereof, with the exception of prefabricated buildings, which are allocated to a separate heading 9406. The boundary between these two headings is often the subject of customs disputes, so exporters must clearly prove that their products are components, not ready-made prefabricated buildings. Heading 7308 includes bridges and bridge sections, lock-gates, towers, lattice masts, roofs, roofing frameworks, doors, windows and their frames, thresholds, balustrades, pillars, columns, as well as specially prepared plates, rods, angles, shapes, sections, and tubes.

The structured distribution of key subcategories that form Ukraine’s export potential is as follows:

In the architecture of customs payments, Ukrainian manufacturers hold a strategic advantage. Within the framework of implementing the Association Agreement between Ukraine and the European Union, as well as in accordance with intergovernmental agreements with the states of the European Free Trade Association (EFTA), a preferential import duty rate of 0% applies to goods of heading 7308 (duty preference “403”). This rate creates powerful financial leverage for Ukrainian companies, allowing them to compete with manufacturers from Asia or the Middle East.

However, the zero rate is not applied automatically. Its activation requires the provision of a EUR.1 certificate of origin, which confirms that the goods comply with the rules of preferential origin (sufficient level of processing in the customs territory of Ukraine). Any inaccuracies in the accompanying documentation, discrepancies in weight, or incorrect indication of UKT ZED codes can lead to the cancellation of the preferential regime, the accrual of full import duty, and the halt of customs clearance at the EU border.

Deep Integration of Transit Systems: Transition to NCTS Phase 5

Customs logistics is a critical pricing element for metal structures, which are often characterized by non-standard dimensions and substantial weight. Successful delivery to a European customer is impossible without the use of common transit. Ukraine’s integration into the European customs space began with its accession to the Convention on a Common Transit Procedure in the autumn of 2022, which officials and business dubbed the “customs visa-free regime”. This step made it possible to move goods from a Ukrainian enterprise to their destination in the EU using a single transit document.

However, the European customs IT infrastructure does not stand still. To modernize data exchange architecture and ensure full digitalization of processes, participating countries of the Convention pledged to transition to a new generation of the electronic system. Ukraine demonstrated an unprecedented speed of adaptation, transitioning to the updated version of the European transit system — NCTS Phase 5 — on April 22, 2024. This transition was a complex technological operation that required over 500 test scenarios with customs authorities of different countries, adaptation of legislation, and updates to brokerage software supported by the EU4PFM program. As of January 21, 2025, this system became mandatory for all 36 participating countries of the Convention.

For exporters of metal structures, the transition to NCTS Phase 5 represents a conceptual shift in approaches to cargo consolidation. The previous version (Phase 4) has stopped accepting new declarations, and businesses must adapt to new, more detailed data formats. The main advantage of the fifth phase is the ability to declare hierarchically, breaking down information to the level of House Consignments. This allows declaring up to 1999 separate shipments within a single T1 transit declaration.

The practical dimension of this innovation is immense: a Ukrainian factory can load various metal structure elements into one truck (e.g., stairs for one customer in Poland, beams for another in Germany, and facade systems for a third in France), and the system will allow detailed tracking and processing of each batch separately without the need for unloading and re-registering at intermediate customs offices.

The declaration submission procedure has become completely electronic and is carried out via the Trader Portal, the government’s “Single Window” service, or directly from brokerage software like QDPro. The algorithms for completing a T1 declaration in Phase 5 require strict synchronization of security identifiers with the Entry Summary Declaration (ENS) or Exit Summary Declaration (EXS). The data entry accuracy requirements have become much stricter as the system automatically validates information on a pan-European level. Thus, border crossing speed is now directly proportional to the quality of electronic data preparation by the enterprise’s customs brokers.

The Regulatory Foundation of Safety: Production Certification according to EN 1090 and CE Marking

Customs clearance is only a logistical stage. The fundamental condition for admitting any building metal structures into the internal market of the European Union is their compliance with strict safety standards, evidenced by the application of the CE marking (Conformité Européenne). According to Article 114 of the Treaty on European Union and the basic Construction Products Regulation (until recently CPR 305/2011), the CE marking is legal proof that the product poses no threat to life, health, and the environment.

For load-bearing steel and aluminum structures, the process of obtaining the right to such marking is regulated by the harmonized European standard EN 1090-1 (“Execution of steel structures and aluminium structures. Part 1: Requirements for conformity assessment of structural components”). Since the beginning of 2023, Ukraine, as part of harmonizing its legislation with Europe’s, has extended this regulation not only to exports but also to the domestic market, leveling the playing field and raising overall quality levels.

The foundational principle of the EN 1090 standard is a risk-oriented approach. All building structures are divided into four Execution Classes (EXC), reflecting potential hazards in the event of structural failure. The level of technical requirements, inspection volume, and tolerance stringency increase exponentially from EXC1 to EXC4.

Most galvanized and load-bearing metal structures currently exported from Ukraine fall under EXC2 and EXC3 classes. For these classes, self-declaration of conformity is strictly prohibited — the Ukrainian manufacturer is obliged to engage an independent European notified body for conformity assessment (NB). The choice of NB is critical. The body must have a unique identification number assigned by the European Commission and the authority to conduct audits specifically under the EN 1090-1 standard. The most authoritative in the market are TÜV Thüringen (number 0090), Bureau Veritas, DAKC, Kiwa, Lloyd’s Register, and DNV. Attempts to cooperate with unaccredited intermediaries are guaranteed to lead to certificate revocation and export bans.

The certification procedure is lengthy, organizationally complex, and usually takes from 6 to 18 months of continuous work by the entire enterprise. The algorithm includes the following strategic steps:

1. Conducting Initial Type Testing (ITT) and Initial Type Calculations (ITC). The company must prove that its design and engineering departments are capable of designing products that withstand specified loads according to Eurocodes.
2. Development and implementation of a Factory Production Control (FPC) system. This is the core of the EN 1090 standard. FPC requires full documentary recording of all production processes. The system must cover personnel management, verification and calibration schedules for all measuring and welding equipment, non-conformity (defect) management with corrective actions, subcontracting procedures, and strict control of input materials. Experts emphasize that an active ISO 9001 quality management system at the enterprise provides the necessary foundation for swift FPC implementation.
3. Production Audit. NB experts verify all documentation and conduct an on-site audit directly at the metal structure manufacturing facility.
4. Emission of the Declaration of Performance (DoP). After a successful audit, the NB issues a Certificate of Conformity of the Factory Production Control. Only based on this certificate does the manufacturer obtain the right to independently draft a DoP and affix the CE mark to the product. The Declaration is a legal document that accompanies the cargo to the customer in the EU and contains all key parameters, including compliance with protective coating standards (e.g., hot-dip galvanizing per EN ISO 1461).

It should be understood that the EN 1090 certificate is not a one-time achievement. Although it is valid indefinitely, its validity is maintained through mandatory surveillance audits. The frequency of audits depends on product complexity: for EXC1 and EXC2 classes, inspections follow a pattern of 1, 2, 3 years, and then every 3 years thereafter, whereas for EXC3 and EXC4 classes, the requirements are stricter — 1, 1, 2, 3 years, and then every 3 years thereafter. This mechanism ensures that the manufacturer does not lower quality standards after gaining access to the EU market.

Synchronization of Technologies: Welding Management (ISO 3834) and Metal Traceability (EN 10204)

A metal structure is, essentially, an assembly of rolled metal, joined by welds. Accordingly, European legislation pays unprecedented attention to two factors: welding quality and the physicochemical properties of the input raw material.

The EN 1090 standard does not contain detailed instructions on welding; instead, it imperatively refers to a set of international standards ISO 3834 (“Quality requirements for fusion welding of metallic materials”). If FPC under EN 1090 controls the plant as a whole, ISO 3834 focuses exclusively on the metallurgical physics of the welding process. The depth of ISO 3834 implementation directly depends on the structure’s execution class:

1. EXC1 requires compliance with EN ISO 3834-4 (elementary quality requirements).
2. EXC2 requires compliance with EN ISO 3834-3 (standard quality requirements).
3. EXC3 and EXC4 compel the manufacturer to comply with EN ISO 3834-2 (comprehensive quality requirements).

For the exporter, this means the need for massive investments in personnel and technologies. Every welder at the enterprise must be certified under the ISO 9606-1 standard, and welding machine operators under ISO 14732 by a European notified body. Each type of welded joint must have a qualified Welding Procedure Specification (WPQR) in accordance with ISO 15614 or ISO 15613. Control over these processes cannot be carried out by a regular foreman; the standard requires the appointment of a certified welding coordinator (according to EN ISO 14731) and independent non-destructive testing specialists (ultrasonic, X-ray, magnetic particle methods) certified under the ISO 9712 standard.

A separate, no less critical aspect of certification is material traceability. The quality of the most advanced weld is nullified if the steel product has internal defects or an inappropriate chemical composition. Technical requirements for steel (EN 1090-2) and aluminum (EN 1090-3) structures mandate the Ukrainian manufacturer to use only raw materials whose origin and characteristics can be proven with 100% certainty.

The European benchmark for metal accompanying documentation is the EN 10204 standard (“Metallic products – Types of inspection documents”). It defines the hierarchy of certificates that a metallurgical plant provides to the buyer. Understanding this hierarchy is a matter of survival for a Ukrainian metal structures plant:

In order to export metal structures of EXC2 and EXC3 classes, a Ukrainian manufacturer must purchase rolled products from metallurgists exclusively accompanied by EN 10204 type 3.1 certificates. This document contains data on chemical analysis (in particular, the carbon equivalent CEV, which determines steel weldability) and confirms mechanical properties after rolling or heat treatment. During an EN 1090 audit, the NB inspector will necessarily check whether the markings on a steel beam (melt numbers) allow tracing its path from the finished product back to the ladle at the metallurgical plant, using precisely the 3.1 certificate. The absence of this document makes it impossible to apply the CE mark.

The Sustainability Revolution: The New EU Construction Products Regulation (CPR 2024/3110)

If the EN 1090 and EN 10204 standards form the current barrier to market access, then radically updated European legislation shapes the contours of the future market. For a long time, European directives focused primarily on mechanical safety and fire resistance of buildings. However, under the European Green Deal, priorities have changed. In November 2024, the European Parliament and the Council of the EU adopted, and in December 2024 published, the new Construction Products Regulation (EU) 2024/3110 (CPR). This document replaces the outdated regulation 305/2011/EU and marks the greatest transformation of the industry in the last fifteen years.

The new CPR entered into force on January 7, 2025. Realizing the scale of the changes, the European Commission has provided for a long transition period: most requirements will begin to apply on January 8, 2026, penalties and environmental checks will intensify in 2027, and the final repeal of the old regulation will take place only in 2040. However, for manufacturers, this is no reason to delay. The European Commission has determined priority groups of goods to which the new rules will apply first. This list (for 2026-2029) includes products with a high carbon footprint: metal building structures (steel and aluminum), rebar, cement, precast concrete, and insulation materials.

The new CPR 2024/3110 shifts the focus of CE marking from purely mechanical characteristics to parameters of environmental sustainability, the circular economy, and total digitalization of supply chains. For Ukrainian exporters, this means the need to prepare for three fundamental innovations:

1. Extended Declaration of Performance and Conformity (DoPC). The traditional DoP, which contained only technical parameters, is being replaced by the DoPC. Henceforth, a metal structures manufacturer is obligated to disclose full environmental and climate data of its product. This includes a mandatory report on the carbon footprint (Global Warming Potential – GWP), energy consumption during production, use of recycled materials, repairability, toxicity, and recyclability. To generate such data, enterprises will be forced to conduct deep Life Cycle Assessments (LCA) and issue Environmental Product Declarations (EPD) in accordance with the European standard EN 15804.
2. Mandatory Digital Product Passport (DPP). Paper document flow is a thing of the past. The new CPR introduces a requirement to create an electronic repository for each batch of products. The digital passport will integrate all technical documentation (drawings, calculations, EN 1090 and EN 10204 certificates) and environmental data (EPD) in a single database, accessible via a standard QR code or a chip attached to the steel beam itself. This passport must be fully compatible with Building Information Modeling (BIM) systems currently used by European architects and general contractors.
3. Strengthening of Surveillance and the AVCP system. A new, most stringent level — AVCP 3+ — is being added to the existing systems of conformity assessment. It mandates involving European notified bodies not only for welding checks but also for validating the manufacturer’s environmental claims. In case of falsified environmental data, severe sanctions will be applied. Moreover, the regulation broadens the circle of responsible parties: henceforth, online marketplace operators and fulfillment service providers will bear joint liability for the sale of uncertified building materials.

The consequences of these changes are obvious: in the coming years, European public procurement and private developers will refuse metal structures that lack verified environmental reporting in DPP format, even if their price is significantly below the market.

Climate Protectionism: The Impact of the Carbon Border Adjustment Mechanism (CBAM)

The new CPR construction regulation is closely linked to another super-powerful tool of European climate policy, which poses a direct threat to the financial stability of Ukrainian metallurgy — the Carbon Border Adjustment Mechanism (CBAM).

Approved as part of the “Fit for 55” package (aimed at reducing emissions in the EU by 55% by 2030), CBAM aims to equalize the environmental costs of European manufacturers, who are forced to buy expensive emission allowances, with importers from countries where environmental legislation is liberal. This is a classic mechanism to prevent “carbon leakage”.

The transition period, during which importers only reported the volumes of embedded CO2 emissions without financial obligations, is coming to an end. From January 1, 2026, the mechanism will operate at full capacity. A European importer of Ukrainian metal structures (ferrous metals and aluminum are in the focus of the first wave of regulation) will be required to buy CBAM certificates for every ton of embedded greenhouse gas emissions. Starting February 1, 2027, the cost of these certificates will be determined by the market price of allowances on the European Union Emissions Trading System (EU ETS), which stably remains at a high level. From 2028, the mechanism is planned to be extended to an additional 180 product categories, including ready-made aluminum facade systems, windows, and doors.

The economic impact of CBAM on Ukraine is calculated to be devastating. Analysts from the Institute for Economic Research (IER) forecast that the implementation of this mechanism could cost the Ukrainian economy $1.4 billion in lost export revenues between 2026 and 2027. In its calculations, the European Commission significantly underestimated this impact, predicting a drop in Ukraine’s GDP of only 0.01% by 2035. Realistic models by domestic experts point to the risk of a GDP collapse of up to 2.1% by 2030. The European Commission’s mistake lay in applying “default values” for emissions to Ukrainian plants instead of calculating actual ones.

Herein lies the main risk for the Ukrainian exporter. If a metal structure plant cannot provide a European partner with independently audited data on actual direct and indirect CO2 emissions (which it must gather for the new CPR anyway), EU customs authorities will automatically apply default values. The default values are intentionally calculated as the worst indicators globally. Their application will lead to an increase in the cost of Ukrainian metal structures by 10–25% (approximately 86–100 euros of additional financial burden for each ton of steel). Such a price hike will instantly make domestic products uncompetitive.

A reduction in CBAM payments is possible exclusively through structural modernization: transition from open-hearth and basic oxygen steelmaking to electrometallurgy (electric arc furnaces), the use of renewable energy, and the provision of a completely transparent, European model of environmental monitoring.

Sanctions Restrictions: Traceability and Proof of Non-Russian Origin

Besides technical and environmental barriers, Ukrainian metal structure exporters must navigate a complex labyrinth of geopolitical sanctions. EU Council Regulation No. 833/2014, adopted in response to the Russian Federation’s aggression against Ukraine, establishes comprehensive economic restrictions. This regulation has a direct and very severe impact on the supply chains of the European construction market.

According to the provisions of Article 3g of Regulation 833/2014, it is categorically prohibited to import iron and steel products into the European Union (in particular, classified under UKT ZED code 7308), if they are manufactured using Russian metallurgical raw materials or semi-finished products (slabs, billets, hot-rolled coils). The key nuance is that this prohibition acts extraterritorially: if a Ukrainian plant purchased steel products of unknown origin on the secondary market, manufactured a complex metal structure out of it, and sent it to the EU, European Union customs authorities have the full right to confiscate this cargo if a Russian trace is found in the primary raw material.

For Ukrainian business, this creates an unprecedented legal collision. A EUR.1 certificate of origin only proves that the metal structure as an end product has “Ukrainian origin” due to a sufficient level of processing in the territory of Ukraine. However, it does not prove the country of origin of the input metal. To pass sanctions control, European customs officers demand the provision of full documentary supply chain traceability (Mill Test Certificates). And it is exactly here that the critical importance of having an EN 10204 type 3.1 certificate manifests itself again. This document from the metallurgical plant not only confirms yield strength for EN 1090 certification, but also clearly identifies the metal manufacturing plant and melt number, serving the function of a “safety passport” under the conditions of Regulation 833/2014.

Trade Quotas and Macroeconomic Risks in the EU Market

Despite public solidarity with Ukraine, the European Union remains a union that strictly protects its domestic producers. Amid an energy crisis, inflation, and stagnation in the construction sector, European metallurgists are exerting strong lobbying pressure on the European Commission to restrict imports.

Safeguard measures in the EU steel market, functioning within the rules of the World Trade Organization (WTO), are based on a system of tariff quotas. Any import exceeding the established quota is subject to a prohibitive duty (usually at 25%). The information space regularly captures initiatives to strictly limit access for Ukrainian metal products. For instance, proposals were discussed to set a duty-free quota for Ukraine at a level of only 713 thousand tons of metal products per year. Considering that in 2025 Ukrainian companies exported 2.65 million tons of steel to the EU, implementing such proposals would mean a shocking 70% reduction in export volumes.

For Ukraine’s economy, such a decision would lead to direct losses of about 1 billion euros in revenue. While quotas primarily apply to raw and semi-finished rolled products, finished metal structures directly depend on this environment. The introduction of individual “specific measures” against certain countries, occasionally announced by European officials, creates a high level of investment uncertainty. The conclusion of long-term contracts for supplying metal structures to European construction megaprojects is complicated if an exporter cannot guarantee that its products will not fall under sudden sectoral sanctions or prohibitive duties due to national quota exhaustion.

Strategic Conclusions and Compliance Architecture

An analysis of the regulatory, customs, and political environment of the European Union as of 2026 allows stating a fundamental change in the rules of the game. The era, when exporting metal structures was possible solely due to cheap labor, the availability of a domestic ore base, and simple geographical proximity, has irrevocably ended. The EU market has transformed into a highly intellectual, extremely bureaucratized, totally digitized, and environmentally dictatorial ecosystem.

Non-tariff barriers have completely replaced financial duties as the main tool for screening imports. To do business successfully and gain stable access to the European construction market, a Ukrainian metal structures manufacturer must evolve from a traditional metalworking plant into a modern IT and engineering company. A successful corporate export strategy must be based on five pillars of compliance:

1. Engineering and Production Certification: Unconditional implementation of the FPC system, passing the audit, and maintaining a certificate from an authoritative European notified body (TUV, DNV, Bureau Veritas) according to the EN 1090-1 standard for the relevant execution class (EXC2 or EXC3).
2. Total Control of Welding Processes: Full integration of ISO 3834 requirements into the production cycle. Investment in continuous training and European certification of welders (ISO 9606) and non-destructive testing operators (ISO 9712).
3. Safety and Transparency of Supply Chains: Refusal to buy rolled metal without proper documentation. Sourcing raw materials exclusively accompanied by EN 10204 type 3.1 certificates, which guarantees the confirmation of mechanical properties and a legal (non-Russian) origin of the metal.
4. Synchronization with Environmental Legislation: Immediate preparation for the CPR 2024/3110 regulation requirements. This necessitates conducting Life Cycle Assessments (LCA), preparing Environmental Product Declarations (EPD) to form the extended Declaration of Performance and Conformity (DoPC), and creating a Digital Product Passport (DPP). Concurrently, an accurate audit of the enterprise’s carbon footprint is essential to minimize CBAM payments.
5. Logistical Optimization: Integration of brokerage units with the NCTS Phase 5 system, using the House Consignment mechanism for flexible and cost-effective consolidated cargo transportation to European clients.

The survival and prosperity of the Ukrainian metal structures industry will depend on the speed with which business owners realize that CE marking today means not only a robust weld, but also responsibility for every ton of CO2 emissions, recorded on a digital blockchain.