The UK government recently amended its Russia Regulations, The Russia (Sanctions (EU Exit) (Amendment) Regulations 2023 “the 2023 Regulations”), and—along with several other measures—introduced a prohibition on the import of certain Russian iron and steel products processed in a third country (or multiple third countries).

The ban on third-country processed iron and steel is set out in Regulation 46IA and 46IB, found in Chapter 4CA of Part 5 of the 2023 Regulations. Third-country processing can be a means of concealing the Russian origin of iron and steel products. This measure is targeted at reducing circumvention of sanctions on Russian iron and steel.

The prohibition on the import of Russian iron and steel products processed in a third country will come into effect from 30 September 2023. As the measure was introduced in the 2023 Regulations in April, there will be no exceptions or transitional period for any covered goods.

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);
• the date that the iron and steel product left its country of origin; and
• 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.

Traders seeking to import banned iron and steel processed in the third country into the UK after the 30 September 2023 effective date can apply for a licence.

The UK government issued a Guidance on third country processed iron and steel measures that seeks to explain the scope of the measures related to relevant Russian iron and steel processed in third countries only. This includes scenario-based explanations that importers can use to determine the prohibitions that could apply to their products.