UK to introduce sanctions on Russian iron and steel processed in third countries
UK regulations banning the import of Russian iron and steel products processed in a third country will take effect on 30 September, the Department for International Trade said in a guidance notice.
‘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,’ said the notice, issued jointly with the Department for Business & Trade on 8 September.
It explained that because the regulation was introduced in April, ‘There will be no exceptions or transitional period for any goods covered by the measure.’
The guidance explains the scope of the measures related to relevant Russian iron and steel processed in third countries only, and the evidence traders need to provide to demonstrate compliance.
‘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,’ it advised.
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 all the countries or facilities 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,’ according to the guidance, which includes scenarios of how these rules may apply in practice.
