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DBT & EU issued revision on Guidance on Third-Country processing of iron and steel regulation

At the end of February, both the UK and EU issues similar updates regarding the measures related to Russian iron and steel processed in 3rd countries only, and the evidence traders must provide to demonstrate compliance.  This has also had a further update on the 1st March 2024.

Importing from the EU

UK traders importing iron and stell products from the EU into the UK will no longer be required to demonstrate evidence of supply chain history at the point of import to demonstrate compliance with the sanctions.  This should facilitate the import process at the border of non-sanction iron and steel although important to note that other customs arrangements continue to apply.    Sanctioned iron and steel can only be imported if the trader has a licence (including a general guidance).   

The HS codes in scope of this arrangement are listed at the bottom of this page, with the following exceptions:

  • for HS code 7207 11, this arrangement will apply from 1st April 2024

  • for HS codes 7207 12 10 and 7224 90, this arrangement will apply from 1st October 2024

For traders, it is also worth noting the guidance related to demonstrating supply chain history, which may include documentation where it shows the origin of the iron and steel products processed in 3rd countries,  the date the goods left the country of origin and the country and facilities where the processing takes place.    Evidence may include although not limited to a Mill  Test Certificate (MTC) where the relevant information cannot be summarised in a single document.   Other documents which could be provided as evidence may include:  invoices, bill of lading,  a CMR Transport document or other book document related to the goods, as well as Certificates of Origin issued by a Chamber of Commerce -  Greater Manchester Chamber can help you with this!  Simply contact our team at 

Read further UK guidance, please click here

EU Guidance for imports to the EU from the UK

On their update issued on the 23rd February, the EU added the UK to a list of partner countries that apply restrictive measures on imports of iron and steel from Russia and a range of import control measures that very similar to those of the EU.    The article 3g has been respectively amended and now reads “For the application of this point, at the moment of importation, importers shall provide evidence of the country of origin of the iron and steel inputs used for the processing of the product in a third country unless the product is imported from a partner country for importation of iron and steel as listed in Annex XXXVI”

These updated measures by the UK and EU should facilitate ongoing flow of trade between them for goods falling under these regulations and reaffirms the commitment to implement measures to guarantee the exclusion of iron and steel from Russia in the manufacturing process of these goods.

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