Certain products made out of Russian iron and steel that have been processed in a third country will now be banned from importing. Specific details on the ban are set out in Regulation 46IA and 46IB, which can be found in Chapter 4CA of Part 5 of the 2023 Regulations. The latest change to regulations will come into effect on 30 September 2023.

The goods affected by the new Regulation are defined under Schedule 3B of the Russia Sanctions Regulations. They will have to meet the following criteria:

• Have been “altered, transformed in any way; or subjected to any type of operation or process” in a third country
• Incorporate one or more Schedule 3B iron and steel products of Russian origin

As a consequence, importers and traders should prepare to have available documents to demonstrate the imported goods’ supply chain. Proofs required 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
• Mill Test Certificate/s (MTC/MCTs) where the relevant information cannot be summarised in a single document.

We will continue to monitor the situation and provide further updates. Should you have any question or concerns on your global supply chain or, please reach out to us here.