The Personal Injuries (NHS Charges) (Information Provision and Amounts) (Amendment) Regulations 2026
Expanded trade sanctions to prohibit the import of Russian iron and steel products processed in third countries starting December 2024.
These Regulations amend the Russia (Sanctions) (EU Exit) Regulations 2019 to expand trade restrictions on iron and steel products.
The instrument prohibits the import of specified iron and steel products that have been processed in a third country using Russian-origin materials.
It also introduces new definitions for 'relevant processed iron or steel products' and updates the list of prohibited items in Schedule 3B. The Secretary of State is granted the authority to issue licenses for activities that would otherwise be prohibited under these new measures.
Arguments For
The explanatory memorandum states that these measures aim to disrupt Russian revenue streams by addressing circumvention routes for iron and steel products.
The document notes that the amendments align UK sanctions with international partners to ensure a coordinated approach to trade restrictions.
Proponents within the government argue that expanding the definition of restricted goods is necessary to respond to evolving trade patterns that bypass existing sanctions.
The regulations specify that licensing remains available for specific transactions, providing a mechanism for the Secretary of State to mitigate unintended economic impacts.
Arguments Against
Legal commentators have noted that the complexity of determining the origin of processed iron and steel in third-country factories may increase compliance costs for UK importers.
Industry bodies have expressed concern regarding the administrative burden of providing evidence of origin for complex supply chains.
Some legal experts suggest that the broad definition of 'relevant processed iron or steel product' could lead to uncertainty for businesses operating in global manufacturing hubs.
Critics of the sanctions regime may argue that the effectiveness of these measures depends on the rigorous enforcement by third-country authorities, which is outside UK jurisdiction.
1. Citation and commencement
(1) These Regulations may be cited as the Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2024. (2) These Regulations come into force on 6th December 2024.
This section establishes the official title of the legal instrument and sets the date on which the new rules become active. All businesses and individuals subject to UK law must comply with the amendments starting from 6 December 2024.
2. Amendment of the Russia (Sanctions) (EU Exit) Regulations 2019
The Russia (Sanctions) (EU Exit) Regulations 2019 are amended as set out in regulations 3 to 5.
This provision confirms that the 2024 Regulations serve to modify the existing 2019 framework for Russian sanctions.
It indicates that the specific changes are detailed in the following sections of this document.
3. Interpretation of Part 5 (Trade)
In regulation 21(1) (interpretation of Part 5), in the definition of "relevant processed iron or steel product", for "is listed in" substitute "falls within a commodity code listed in".
This section clarifies the technical definition of iron and steel products subject to trade restrictions.
By referencing commodity codes rather than just general lists, the law provides a more specific classification system used in international trade to identify prohibited goods.
4. Import of iron and steel products: third country processing
In regulation 46B (import of iron and steel products: third country processing)— (a) in paragraph (1), for "a relevant processed iron or steel product" substitute "a product which is a relevant processed iron or steel product"; (b) after paragraph (3) insert— "(4) For the purposes of this regulation, a product is a relevant processed iron or steel product if it— (a) is listed in Schedule 3B, and (b) has been processed in a third country and incorporates one or more iron or steel products which originated in Russia."
This amendment expands the prohibition on importing iron and steel.
It explicitly bans products listed in the schedule that were manufactured in a country other than Russia or the UK if they contain any iron or steel components originating from Russia.
This aims to prevent the entry of Russian materials into the UK market through secondary manufacturing processes abroad.
5. Amendment of Schedule 3B
In Schedule 3B (Iron and steel products), for the table in Part 4 (Relevant processed iron or steel products) substitute the table in the Schedule to these Regulations.
This section replaces the existing list of controlled items with a new, updated table.
Importers must refer to the new schedule to determine if their specific goods are now subject to these trade restrictions.
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