The National Health Service (Pharmaceutical and Local Pharmaceutical Services) (Amendment) Regulations 2026

Published: Mon 29th Jun 26

These Regulations amend the Russia (Sanctions) (EU Exit) Regulations 2019 to expand the scope of trade and service prohibitions.

The instrument adds 'relevant machinery' to the list of prohibited internal repression goods and technology, effectively banning its export to, or for use in, Russia.

It further refines the existing prohibition on providing legal advisory services to non-UK persons regarding activities that would be illegal if carried out by a UK person.

These measures apply to all persons within the United Kingdom and all United Kingdom persons outside the UK.

Arguments For

The explanatory memorandum states that these measures are intended to encourage Russia to cease actions which destabilise Ukraine, or undermine or threaten the territorial integrity, sovereignty or independence of Ukraine.
The document argues that expanding the definition of 'internal repression goods and technology' to include relevant machinery is necessary to prevent the export of items that could be used by the Russian state for domestic repression.
Proponents indicate that the amendments clarify the scope of existing prohibitions, such as those regarding the provision of legal advisory services to non-UK persons, to ensure the sanctions regime remains effective and enforceable.
The legislation asserts that these changes align with the UK’s broader foreign policy objectives of maintaining international peace and security under the Sanctions and Anti-Money Laundering Act 2018.

Arguments Against

Legal practitioners have noted that the expansion of prohibitions on legal advisory services may create compliance complexities for firms determining whether their advice assists a non-UK person in a prohibited transaction.
Business groups may argue that the addition of 'relevant machinery' to the internal repression goods list increases the administrative burden on exporters who must now screen a wider range of industrial products.
Some legal analysts suggest that the broad definitions of 'internal repression' or 'destabilising Ukraine' may lead to legal uncertainty regarding which specific commercial activities fall under the scope of criminal penalties.
Human rights monitors have previously raised concerns that sanctions regimes, while targeting state actors, can have unintended secondary effects on civil society's access to certain technologies.

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 15th December 2024.

This section establishes the official title of the legal instrument and sets the date it becomes legally enforceable.

All provisions contained within the document take effect on 15 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 10.

This provision identifies the 2019 Russia Sanctions as the primary legislation being modified.

It serves as an introductory clause for the specific amendments detailed in the subsequent sections of the document.

3. Amendment of regulation 21 (interpretation of Part 5)

In regulation 21(1) (interpretation of Part 5), in the definition of “internal repression goods and technology”, after paragraph (a) insert—

“(aa) relevant machinery;”.

This amendment expands the legal definition of 'internal repression goods and technology' used in the primary sanctions regulations.

By adding 'relevant machinery' to this category, it subjects those items to the trade restrictions and prohibitions that apply to goods used for domestic repression.

4. Amendment of regulation 54D (legal advisory services)

In regulation 54D (legal advisory services), for paragraph (1) substitute—

“(1) A person must not directly or indirectly provide legal advisory services to any person who is not a United Kingdom person in relation to—

(a) an activity which would be prohibited under any of Parts 3 to 7 (Finance, Trade, Aircraft, Ships and Revenue) if the activity were carried out by a United Kingdom person or had a sufficient connection to the United Kingdom, or

(b) a relevant prohibited activity.

(1A) For the purposes of paragraph (1)(b), a “relevant prohibited activity” is an activity which—

(a) would be prohibited under any of Parts 3 to 7 if the activity were carried out by a United Kingdom person or had a sufficient connection to the United Kingdom, and

(b) is prohibited under the law of any country other than the United Kingdom, where that law—

(i) has a purpose which is the same as, or similar to, any of the purposes of these Regulations, and

(ii) is prescribed for the purposes of this regulation by the Secretary of State.”

This section replaces the existing rules regarding the provision of legal advice to non-UK persons.

It prohibits giving legal advice on activities that would breach UK sanctions if done by a UK person, and extends this to advice on activities that violate similar sanctions laws in foreign countries as prescribed by the Secretary of State.

This restricts the ability of UK legal professionals to facilitate transactions for foreign clients that bypass or mirror violations of the UK's Russia sanctions regime.

5. Amendment of Schedule 2 (internal repression goods and technology)

In Schedule 2 (internal repression goods and technology), after paragraph 4 insert—

“Relevant machinery

All goods specified in the following headings in the goods classification system—

(a) 8413 (pumps for liquids, whether or not fitted with a measuring device; liquid elevators);

(b) 8414 (air or vacuum pumps, air or other gas compressors and fans; ventilating or recycling hoods incorporating a fan, whether or not fitted with filters);

(c) 8479 (machines and mechanical appliances having individual functions, not specified or included elsewhere in Chapter 84 of the goods classification system).”

This section provides the technical specification for 'relevant machinery' by referencing codes from the global goods classification system (Harmonized System).

It explicitly lists liquid pumps, air/vacuum pumps, compressors, fans, and certain miscellaneous mechanical appliances as items now classified as internal repression goods.

This technical detail determines which specific industrial products are subject to the new export bans.

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