06.10.2023
Rundown on Russian Sanctions
Background:
Sanctions on Russian goods have been gradually introduced from March 2022, and have already prohibited the direct and indirect import of:
- Oil and oil products
- Coal and coal products
- Liquefied natural gas
- Certain processed gold (on or after July 2022)
- Goods originating from Russian-occupied territory in Ukraine
What’s New:
Taking effect from September 30th 2023, the Department for Business & Trade (DBT) and the European Union (EU) are strengthening and extending the sanctions regime on the above list, most notably with regard to iron and steel products. Any iron or steel product or material set out in Schedule 3B of the Russia Sanctions Regulations that is of Russian origin is prohibited from being imported.
- You can find more information on the new sanctions, as well as the products and materials being affected, here.
- Unsure if your product is affected? DBT has provided a series of scenarios to help clarify which products are covered under the new rules here.
Measures & Guidance:
- The UK and EU have provided guidance on the obligations that importers/supply chains will need to follow:
- Typically, importers will need to provide evidence of the ‘country of origin’ for the iron and steel inputs used in the processing of products in third countries. DBT have suggested that a 'Mill Test Certificate' may be considered as sufficient evidence.
- Customs authorities in the UK and EU will be alert to the need for the presentation of relevant documents and can request further evidence to demonstrate the burden of proof.
- A failure to present the required documentation will lead to the imports not being cleared through Customs. In the worst circumstances of a failure to comply with these measures, Customs can take enforcement action against the importer, on the basis of a deliberate attempt to break Sanctions rules.
Customs:
- As a single Customs agency, it is expected that HMRC will provide a consistent approach as of 30 September. At this stage, it is expected HMRC will not allow for discrepancies in its approach.
- In EU member states, there is expected to be variation in how each country applies the new rules, due to the phased approach of EU sanctions and local political reactions to the new sanctions.
What We’re Doing:
- UK Steel have been keen supporters for the extension of the previous Russian sanction measures on Iron and Steel inputs. The circumvention of Russian inputs through third countries was seen as an economic threat to UK steel products, particularly if there was evidence of ‘market dumping’.
- The Government's new sanctions regime aims to close loopholes and bolster British steel competitiveness in the face of Russian aggression in Ukraine. Make UK will be working with the Department for Business and Trade (DBT), Government, and our members to ensure proper implementation of the new measures and offer guidance and clarity to members.
Do you require further clarity than what has been provided by the Government guidance? Please reach out to the Make UK Policy Team at [email protected] and we will raise your concerns with the Department for Businesses & Trade.