The UK’s ban on the import of certain Russian iron and steel products processed in a third country/ multiple third countries was introduced on 21 April 2023 as part of a wider package of trade sanctions against Russia. It will come into effect from 30 September 2023.
The government has now published specific guidance on third country processed iron and steel of Russian origin to support businesses to comply with the measure. This guidance explains the scope of the ban and the supply-chain evidence businesses can provide to demonstrate compliance.
The guidance on third country processed iron and steel of Russian origin is set out in the Notice to Importers, which should be read alongside the existing Statutory Guidance on sanctions against Russia.
Traders should be aware that there will be no new documentary requirements. Additional documentation may be required if your goods are stopped for compliance checks.
The Notice to Importers clarifies this as follows:
Traders should be prepared to have documentation available to demonstrate evidence of a good’s supply chain, which must be consistent with the prohibitions under the regulations.
Evidence requested to be provided through documentation could include:
- the country of origin of the iron and steel products processed in the third country (or third countries) after the fact
- the date that the iron and steel product left its country of origin
- the country(s) and facility(s) where processing has taken place
An example of evidence may include, but is not limited to, a Mill Test Certificate (MTC), or Mill Test Certificates (MTCs) where the relevant information cannot be summarised in a single document.
Importers are also advised to include assurances that imports are not of Russian origin in contractual agreements.