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New EU ATQ (Master Tariff Quota) draft deletes Russia's qualifications, and Chinese are not affected

The European Commission has added a new clause in the draft autonomous tariff quota (ATQ) system for imported seafood in 2024-25, abolishing the import qualifications of Russian and Belarusian seafood.


The new ATQ covers a number of species popular with European consumers, such as tuna, pollock, hake, shrimp, cod and halibut. These aquatic products are allowed to be imported from non-EU countries in limited quantities without paying tariffs or enjoying lower tariffs. Quota.


The new article reads: “Since July 2014, the European Union has gradually implemented restrictive measures against the Russian Federation. In its conclusions on February 24, 2022, the European Council stated that Russia’s unprovoked and unreasonable military aggression against Ukraine constitutes a serious violation of international law and principles of the United Nations Charter and undermine European and global security and stability."


“On June 23, 2023, the European Commission adopted the eleventh package of sanctions against the Russian Federation for its continued aggression in the war in Ukraine. Although Russia is a member of the World Trade Organization, under the applicable exceptions of the Agreement Establishing the World Trade Organization Circumstances, and in particular Article 21 of the 1994 General Agreement on Tariffs and Trade, the EU grants the Russian Federation the same preferences (most-favored nation treatment) as other countries for imports of products.”



In view of the deterioration of relations between the EU and Russia, and in order to ensure that its actions and principles in the field of external action are consistent with those of the EU, the European Commission considers that "it would not be appropriate to allow duty-free treatment for products imported from the Russian Federation that fall within the scope of this regulation".


Separately, given Belarus’s “broad support” for Russia, the European Commission echoed the sentiment, including the following provision in Article 4 of its draft proposal:


“Tariff quotas do not apply to products originating in Russia or Belarus. In order to determine the origin of products covered by the quotas, non-tariff quotas shall apply in accordance with Article 60 of Regulation (EU) No 952/2013 of the European Parliament and of the Council (EU Customs Code). Preferential rules of origin mean that goods produced in more than one country or region shall be deemed to originate in the country or region where the last substantial and economically reasonable processing or processing was performed.”


The focus of this provision is that Russian cod products processed in China will continue to qualify for EU ATQ.


UCN data shows that the EU ATQ from 2021-23 allows the annual import of 110,000 tons of cod (chilled, frozen or processed), as well as 50,000 tons of frozen cod fillets and 2,000 tons of pickled products at 0% tariff. The 2021-23 ATQ also allows zero-tariff imports of 340,000 tons of pollock (chilled, frozen or processed).

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