Update: Russian Sanctions on Iron and Steel – route to compliance

Good afternoon members,

Thank you for your ongoing support and transparency regarding the challenges faced relating to Russian Sanctions on iron and steel.

We are pleased to share that the Department for Business and Trade has published a General Trade Licence for sanctioned iron and steel, to support businesses in complying with this import sanction.

From 11 December 2023, businesses will be able to use this licence to import certain prohibited goods into the UK that:

  • are used as reusable packaging; 
  • were manufactured or produced before 21 April 2023; or
  • 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. Traders should be prepared to have documentation available to demonstrate compliance with the conditions.

Guidance on the use of the licence, including the conditions, record-keeping requirements and how to declare the goods for customs purposes is available here.

This comes as part of a series of updates on Sanctions that will be relevant for members to be aware of, including an announcement by Minister Ghani, of a new Office of Trade Sanctions Implementation (OTSI) to strengthen enforcement of Russian sanctions.

OTSI will launch in early 2024 once the new legal requirements are in place and will reinforce existing work the government does to ensure UK trade sanctions are adhered to. More detail is available on gov.uk.

If you have any further queries, please email importcontrols@businessandtrade.gov.uk.

We are keen to understand if these new measures are sufficient to unlock the operational challenges businesses have been facing, so please do reach out directly on this to Brinley Salzman – Brinley.Salzmann@adsgroup.org.uk ADS notes that additional guidance and clarification around types of evidence is still seen as a requirement.