Update on customs sanctions against Russia. (UK legal framework)

Sharpened customs sanctions on iron and steel products

In response to Russia’s invasion of Ukraine, the UK government has imposed a range of sanction measures, under The Russia (Sanctions) (EU Exit) Regulations 2019 (‘the Russia Regulations’). The Russia (Sanctions (EU Exit) (Amendment) Regulations 2023 (‘the 2023 Regulations’) amended the Russia 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, which can be found in Chapter 4CA of Part 5 of the 2023 Regulations and will come into effect from 30 September 2023.

The activation of the above mentioned Regulation will have an immediate effect on specific tariff headings of Chapter 72 and 73 as mentioned in the UK Integrated Tariff. The affected HS codes can be found via the website of UK GOV, along with some example scenarios for altered products.

Additional evidence in customs declaration has become essential

Additional document evidence in customs declaration has become essential
As of 30 September 2023, additional proof of origin (in addition to any certificate of origin) must be submitted with each customs declaration for the goods concerned. Only providing certificates of origin, EUR1 certificates and other documents for (non-)preferential origin, will not be accepted by Customs as proof of non-Russian origin. 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.

If the tightening of these sanctions affects your business, we strongly advise you to contact your supplier/manufacturer/customer so that you can receive the correct documentation of the products in time and avoid importing illegal goods from Russia.

Request the right documentation in time

If the tightening of these sanctions affects your business, we strongly advise you to contact your supplier/manufacturer/customer so that you can receive the correct documentation of the products in time and avoid importing illegal goods from Russia.

If you are a customer of ours and your company imports or has goods imported that may be subject to sanctions against iron and steel from Russia, your account manager will contact you.

We understand that you may have questions about this information. We therefore recommend that you read regulations carefully. Still have questions? Our customs experts are happy to help! Please email L.Lockwood@gaston-schul.com for additional advice.