Russian Iron & Steel Sanctions: What You Need to Know

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By Alex Dunbar

It has been announced that starting from September 30th 2023, the UK enforced a ban on the import of third country processed iron and steel of Russian origin.

Third country processing can be a means of concealing the Russian origin of iron and steel products, and this measure is targeted at reducing circumvention of sanctions on Russian iron and steel.

What goods are affected?

The goods affected by this Regulation are defined under Schedule 3B of The Russia (Sanctions) (EU Exit) Regulations 2019.

The regulations prohibit the import into the UK of an iron or 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

What do you need to provide during import?

Traders should therefore 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.


Importers are also advised to include assurances that imports are not of Russian origin in contractual agreements.

For further information, the full Government guidance can be read in full on the website.

If there are any further questions, we will be providing updates as they occur or are happy to offer further clarification if required, so please don’t hesitate to contact our team.