Navigating the UK's Sanctions on Russian Iron and Steel: A Comprehensive Guide
Read our guide on the UK Ban on Russian iron and steel processed in third countries only and the evidence traders need to provide to demonstrate compliance.
This section explains the scope of the measures related to relevant Russian iron and steel processed in third countries only, and the evidence traders need to provide to demonstrate compliance. It does not discuss other prohibitions (including other measures related to Russian iron and steel, except for the section on reuseable packaging under the General Trade Licence).
In reaction to Russia's invasion of Ukraine, the UK government implemented trade, financial, transport, and other restrictions under the Russia (penalties) (EU Exit) Regulations 2019 (the "Russia Regulations").
The Russia (Sanctions (EU Exit) (Amendment) Regulations 2023 ("the 2023 Regulations") amended the Russia Regulations and banned the import of certain Russian iron and steel items processed in foreign countries. This extended on 2022 regulations banning Russian steel and iron imports. Regulations 46IA and 46IB of Chapter 4CA of Part 5 of the 2023 Regulations ban third-country iron and steel processing. This policy aims to reduce Russian iron and steel sanctions circumvention. Third-country processes can make iron and steel look Russian.
On September 30, 2023, third-country-processed Russian iron and steel imports are banned. The April 2023 Regulations did not contain a transitional period or exception for any items covered by the provision.
What are iron and steel products in the UK?
For the purpose of this sanction, a relevant ‘iron and steel product’ is defined as anything specified in Schedule 3B of the Russia Sanctions Regulations. The HS codes for the relevant products are also set out at the end of this guidance.
The regulations prohibit the import into the UK of an iron and steel product, when it meets all the following criteria:
is listed in Schedule 3B of the Russia Sanctions Regulations
has been “altered, transformed in any way; or subjected to any type of operation or process” in a third country (see Regulation 46IA)
incorporates one or more Schedule 3B iron and steel product/products of Russian origin
The following scenarios provide examples of how these rules may be applied in practice (where Country X and Country Y are countries that are not the UK, the Isle of Man, or Russia):
Scenario 1
A product of Russian origin that is a good listed in Schedule 3B when it leaves Russia is then processed in a third country into another good listed in Schedule 3B. Importing this product into the UK is prohibited.
For example, steel slabs (HS 7207) of Russian origin are exported from Russia and enter Country X. Here, they are transformed into hot rolled coils of alloy steel (HS 7225 - 7226) and are of Country X’s origin before being imported into the UK.
The import in this example would be prohibited.
Scenario 2
An item of Russian origin that leaves Russia and through many processing steps in one or more third countries loses its Russian origin before being included in the final transformation phase, but remains a Schedule 3B item. Due to its Russian origin, the final Schedule 3B product cannot be imported into the UK.
Russia exports steel billets (HS 7207) to Country X. They become Country X steel rods (HS 7215) here. These enter Country Y, where they are processed into steel wire (HS 7223) for UK import.
This import would be illegal.
Scenario 3
Once it leaves Russia, a product of Russian origin that is not listed as a good in Schedule 3B is processed in a third nation, turning it into a good listed in Schedule 3B. Because the product that is presently entering the UK contains non-Schedule 3B materials, importing this is not forbidden by the Russia Regulations.
For instance, some pig iron (HS 7201) travels from Russia into Country X. Before being imported into the UK, it is converted here into slabs (HS 7207).
The Russia Regulations would not forbid the import in this instance.
Scenario 4
A product of Russian origin that is a good listed in Schedule 3B when it leaves Russia is then processed in a third country into an entirely different product (a good not listed in Schedule 3B). Importing this into the UK is not prohibited under the Russia Regulations.
For example, coils of stainless steel (HS 7219 – 7220) of Russian origin are exported from Russia and enter country X. Here, they are used to manufacture a car (HS 8703), which is now considered to be of country X origin and is imported into the UK.
The import in this example would not be prohibited under the Russia Regulations.
Guidance on Demonstrating Compliance
Demonstrating supply chain history
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.
Licensing Provisions
After 30 September 2023, traders may apply for a permit to import forbidden third-country iron and steel into the UK. Individual trade sanctions licences are granted or denied by the Secretary of State for Business and Trade. DBT deems some acts to be compliant with the penalties and suitable for a licence. The legislative guideline on Russia sanctions may allow the purchase of iron and steel departed Russia before 21 April 2023.
General Trade Licence
The General Trade Licence for sanctioned iron and steel permits the import into the UK of certain prohibited goods that:
are used as reuseable packaging
were manufactured or produced before 21 April 2023
were previously in free circulation in the United Kingdom
Alongside the import of these goods, the licence permits the provision of certain services and actions related to their import. It may also be used in cases where a trader is unaware of a good’s origin, such that their goods are potentially prohibited. The licence has a record-keeping requirement and each of the three categories above is subject to individual conditions.
Reuseable packaging
The licence permits the import of reuseable packaging, of Russian origin or which is a relevant third country processed iron or steel product, that:
falls within commodity code 7326904000 (pallets and similar platforms for handling goods)
is imported into the United Kingdom for the purpose of facilitating international trade of other goods, whether or not filled with other goods when imported
is not consigned from Russia
If these goods are themselves the object of the import (for example with the purpose of domestic use or sale in the UK), this licence does not permit their import.
Goods manufactured or produced before 21 April 2023
The licence permits the import of any prohibited good that:
is a relevant third country processed iron or steel product
was manufactured or produced before 21 April 2023
beginning with 21 April 2023, has not been located in Russia at any time
Traders should be prepared to have documentation available to demonstrate evidence of a processed iron or steel product’s location before this date. This does not need to demonstrate the precise date of manufacture itself, but that the goods existed and were located outside of Russia before this date. Examples of evidence could include an invoice, bill of lading or sales contract. This is not an exhaustive list, but evidence must be verifiable.
Goods previously in the United Kingdom
The licence permits the import of any good that:
is a relevant third country processed iron or steel product
has previously been in free circulation in the United Kingdom
falls within the same commodity code as it did when it was exported from the United Kingdom
beginning with 21 April 2023, has not been located in Russia at any time
Traders should be prepared to have documentation available to demonstrate evidence of this.
Record keeping
Regulation 76 of the Russia Regulations sets out a requirement to keep a register or record of each act carried out under the authority of a general trade licence. The regulation sets out which details may be necessary and the length of time records should be kept for.
Traders should notify the Secretary of State for the Department for Business and Trade, providing their name (or organisation name), EORI number and the address at which the register or record may be inspected, no later than 30 days after first acting under the authority of this licence. This only needs to be done once, by emailing records.importlicences@businessandtrade.gov.uk. Traders should update the details if there are changes by emailing the same address.
Making a customs declaration using this licence
Traders importing goods under this licence are not required to have documentation available to demonstrate evidence of a good’s supply chain, in order to comply with these sanctions.
Use of this licence entails a customs declaration, using code 9063 and licence number GBSAN0001. Traders cannot use a Declaration by Conduct or an oral declaration to import controlled goods (including sanctioned goods).
HMRC Inspection
Border officials may require supply chain proof from traders. Customs may demand further product details. The products' invoice, bill of lading, or other book or document may be included.
HMRC enforces licencing and investigates potential crimes.
We urge all segments of the UK supply chain for third-country processed iron and steel imports to do due diligence to prevent sanctions circumvention. Not following the sanctions might be a crime. Russia sanctions fines are explained in the statutory advice.
Importers should additionally guarantee non-Russian provenance in contracts.
HS codes in scope for the UK’s import ban on Russian iron and steel processed in a third country
Please refer to Chapter 72 and 73 of the UK Integrated Online Tariff checker for more information on HS codes listed below.
HS code Description
7206 Iron and non-alloy steel in ingots or other primary forms (excluding iron of heading 7203)
7207 Semi-finished products of iron or non-alloy steel
7208 Non Alloy and Other Alloy Hot Rolled Sheets and Strips; Non Alloy and Other Alloy Quarto Plates; Rolled on four faces or in a closed box pass, of a width not exceeding 1250 mm; Rolled on four faces or in a closed box pass, of a width exceeding 1250 mm and of a thickness of 4 mm or more
7209 Tin Mill products; Non Alloy and Other Alloy Cold Rolled Sheets; Electrical Sheets (other than GOES)
7210 Metallic Coated Sheets; Organic Coated Sheets; Tin Mill products; Non Alloy and Other Alloy Quarto Plates
7211 Non Alloy and Other Alloy Hot Rolled Sheets and Strips; Non Alloy and Other Alloy Cold Rolled Sheets; Rolled on four faces or in a closed box pass, of a width exceeding 150 mm and a thickness of not less than 4 mm, not in coils and without patterns in relief
7212 Non Alloy and Other Alloy Hot Rolled Sheets and Strips; Metallic Coated Sheets; Organic Coated Sheets; Tin Mill Products;
7213 Non Alloy and Other Alloy Wire Rod
7214 Non Alloy and Other Alloy Merchant Bars and Light Sections; Rebars; Other bars and rods of iron or non-alloy steel, not further worked than forged, hot-rolled, hot-drawn or hot-extruded, but including those twisted after rolling
7215 Non Alloy and Other Alloy Merchant Bars and Light Sections; Non-alloy and other alloy cold finished bars
7216 Non Alloy and Other Alloy Merchant Bars and Light Sections; Angles, shapes and sections, not further worked than cold-formed or cold-finished
7217 Non Alloy Wire
7218 Stainless steel in ingots or other primary forms; semi-finished products of stainless steel
7219 Stainless Hot Rolled Sheets and Strips
7220 Stainless Hot Rolled Sheets and Strips
7221 Stainless Wire Rod
7222 Stainless Bars and Light Sections
7223 Wire of stainless steel, in coils (excluding Bars and rods)
7224 Steel, alloy, other than stainless, in ingots or other primary forms, semi-finished products of alloy steel other than stainless
7225 Non Alloy and Other Alloy Hot Rolled Sheets and Strips; Non Alloy and Other Alloy Cold Rolled Sheets; Electrical Sheets (other than GOES); Metallic Coated Sheets; Non Alloy and Other Alloy Quarto Plates; Flat-rolled products of other alloy steel, of a width of 600 mm or more
7226 Non Alloy and Other Alloy Hot Rolled Sheets and Strips; Non Alloy and Other Alloy Cold Rolled Sheets; Electrical Sheets (other than GOES); Metallic Coated Sheets; Flat-rolled products of other alloy steel, of a width of less than 600 mm
7227 Non Alloy and Other Alloy Wire Rod
7228 Non Alloy and Other Alloy Merchant Bars and Light Sections; Non-alloy and other alloy cold finished bars
7229 Other bars and rods of other alloy steel; angles, shapes and sections, of other alloy steel; hollow drill bars and rods, of alloy or non-alloy steel; Other bars and rods of other alloy steel; angles, shapes and sections, of other alloy steel; hollow drill bars and rods, of alloy or non-alloy steel
7301 Angles, shapes and sections; Sheet Piling
7302 Railway Material
7303 Tubes, pipes and hollow profiles, of cast iron
7304 Seamless Stainless Tubes and Pipes; Other Seamless Tubes
7305 Large welded tubes
7306 Other Welded Pipes
7307 Tube or pipe fittings, for example “couplings, elbows, sleeves”, of iron or steel
7308 Structures and parts of structures, for example “bridges and bridge-sections, lock-gates, towers, lattice masts, roofs, roofing frameworks, doors and windows and their frames and thresholds for doors, shutters, balustrades, pillars and columns”, of iron or steel; plates, rods, angles, shapes, sections, tubes and the like, prepared for use in structures, of iron or steel (excluding Prefabricated buildings of heading 9406)
7309 Reservoirs, tanks, vats and similar containers, of iron or steel, for any material “other than compressed or liquefied gas”, of a capacity of > 300 l, not fitted with mechanical or thermal equipment, whether or not lined or heat-insulated (excluding Containers specifically constructed or equipped for one or more types of transport)
7310 Tanks, casks, drums, cans, boxes and similar containers, of iron or steel, for any material “other than compressed or liquefied gas”, of a capacity of <= 300 l, not fitted with mechanical or thermal equipment, whether or not lined or heat- insulated, n.e.s.
7311 Containers of iron or steel, for compressed or liquefied gas (excluding Containers specifically constructed or equipped for one or more types of transport)
7312 Stranded wire, ropes, cables, plaited bands, slings and the like, of iron or steel (excluding Electrically insulated products and twisted fencing wire and barbed wire)
7313 Barbed wire of iron or steel; twisted hoop or single flat wire, barbed or not, and loosely twisted double wire, of a kind used for fencing, of iron or steel
7314 Cloth, incl. Endless bands, grill, netting and fencing, of iron or steel wire, expanded metal of iron or steel (excluding Woven products of metal fibres of a kind used for cladding, lining or similar purposes)
7315 Chain and parts thereof, or iron or steel (excluding Watch chains, necklace chains and the like, cutting and saw chain, skid chain, scraper chain for conveyors, toothed chain for textile machinery and the like, safety devices with chains for securing doors, measuring chains)
7316 Anchors, grapnels and parts thereof, of iron or steel
7317 Nails, tacks, drawing pins, corrugated nails, staples and similar articles of iron or steel, whether or not with heads of other material (excluding Such articles with heads of copper and staples in strips)
7318 Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers, incl. Spring washers, and similar articles, of iron or steel (excluding Lag screws, stoppers, plugs and the like, threaded)
7319 Sewing needles, knitting needles, bodkins, crochet hooks, embroidery stilettos and similar articles, for use in the hand, of iron or steel; safety pins and other pins of iron or steel, n.e.s.
7320 Springs and leaves for springs, of iron or steel
7321 Stoves, ranges, grates, cookers, incl. Those with subsidiary boilers for central heating, barbecues, braziers, gas rings, plate warmers and similar non-electric domestic appliances, and parts thereof of iron or steel (excluding Boilers and radiators for central heating, geysers and hot water cylinders)
7322 Radiators for central heating, not-electrically heated, and parts thereof, of iron or steel; air heaters and hot-air distributors (incl. Distributors which can also distribute fresh or conditioned air), not-electrically heated, incorporating a motor-driven fan or blower, and parts thereof, of iron or steel
7323 Table, kitchen or other household articles, and parts thereof, of iron or steel; iron or steel wool; pot scourers and scouring or polishing pads, gloves and the like, of iron or steel (excluding Cans, boxes and similar containers of heading 7310; waste baskets; shovels, corkscrews and other articles of the nature of a work implement; articles of cutlery, spoons, ladles, forks etc. Of heading 8211 to 8215; ornamental articles; sanitary ware)
7324 Sanitary ware, and parts thereof, of iron or steel (excluding Cans, boxes and similar containers of heading 7310, small wall cabinets for medical supplies or toiletries and other furniture of chapter 94, and fittings)
7325 Articles of iron or steel, cast, n.e.s.
7326 Articles of iron or steel, n.e.s. (excluding Cast articles)
More information and links
Government Guidance
UK: Sanctions Legislation Against Russia
Get a quick summary of the UK laws applicable in the Sanctions Regime against Russia + Summary
UK: Import Sanctions Against Russia
Import prohibitions are in force under the Russia Sanctions Regulations 2019. We explain what businesses importing goods need to know. https://www.customsmanager.info/post/uk-import-sanctions-against-russia-update
UK: Economic Sanctions Against Russia
We collect and update all relevant information on UK Economic Sanctions against Russia on one detailed page.
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