Following an announcement by the Department for Business and Trade and the Department of International Trade this week, additional measures will come into force on 30th September 2023 in relation to the import of iron and steel goods originating in Russia, and where the metals have been processed in a third country.

The measure is targeted at reducing circumvention of sanctions on Russian iron and steel classified under commodity codes within chapters 72 and 73 of the UK Tariff. There are no exceptions and there is no transitional period for any goods covered by the measure.

To adhere to these additional measures, you must be able to provide documentation to evidence the goods’ supply chain.

Evidence requested could include:

  • the country of origin of the iron and steel products processed in the third country(s)
  • the date that the iron and/or steel product left its country of origin;
  • the country(s) and facility(s) where processing has taken place.

Examples of documentation may include, but are not limited to, a Mill Test Certificate (MTC), an invoice, bill of lading, or other document relating to the goods.

Note: you may be asked to present the evidence of the good’s supply chain at the border at the time of import.

An image of a shipping dock with imported goods

We strongly recommend that you follow HMRC’s advice ‘to undertake the necessary due diligence to ensure that sanctions are not being circumvented directly or indirectly’. Importers are also advised to include assurances that imports are not of Russian origin in contractual agreements.

Failure to comply with the sanctions could constitute one of several criminal offences resulting in financial penalties, imprisonment, or both.

Further information on the sanction, including a list of the goods within chapters 72 and 73, can be accessed by following this link: Third country processed iron and steel

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For further assistance and advice contact Adam at Barbourne Brook by email on
or telephone 01905 914031.

About Barbourne Brook

Barbourne Brook are a proactive team of customs duty planning experts with a wealth of knowledge and insight in the customs sphere, offering scalable solutions backed by industry-leading technology.

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+44 (0)1905 914031


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