On Monday 11 December 2023, the UK Government updated its Notice to Importers (see here), published a new General Trade Licence (see here) and updated its guidance (see here) in relation to the UK’s iron and steel sanctions targeting Russia.
As noted in our previous blog in April 2023, the UK introduced sanctions imposing a prohibition on the import of iron and steel products where the metal originated in Russia but was processed in a third country (i.e. not the UK, Isle of Man or Russia), and technical assistance, financial and brokering services relating to such products. These restrictions came into force on Saturday 30 September 2023.
The UK’s guidance states that traders should be prepared to provide documentation to demonstrate evidence of a good’s supply chain and that the good is compliant with these restrictions. The updated guidance states that Mill Test Certificates are sufficient for these purposes, and now also notes that other evidence could include an invoice, a certificate of origin issued by a chamber of commerce, a bill of lading, or a CMR transport document.
Under the new General Trade Licence, businesses can import reusable packaging, goods manufactured pre-sanctions, and goods that have been in free-circulation in the UK pre-sanctions. The General Trade Licence is available from 11 December 2023 for an indefinite duration. Parties using this General Trade Licence are required to make a notification to the Secretary of State for the Department for Business and Trade within 30 days of first use of the licence, and are subject to record keeping requirements.
