NTI 2946: Iran (nuclear weapons) import sanctions
Updated 8 September 2026
This notice provides an overview of the import prohibitions in force on certain goods imported into the UK, including Northern Ireland, that originate in or have been consigned from Iran. It also sets out the licensing process for traders looking to import goods subject to prohibitions.
It should be read alongside the statutory guidance. In case of conflict with the statutory guidance published by the FCDO, the statutory guidance will prevail.
Background
The Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019 came into force on 1 January 2021 and replaced, with substantially the same effect, relevant existing EU legislation, corresponding prohibitions in the Open General Import Licence (OGIL) and related UK regulations.
The Regulations impose financial, trade and immigration sanctions for the purpose of:
- giving effect to the United Kingdom’s obligations under United Nations Security Council Resolution 2231 (2015) (‘UNSCR 2231’)
- the additional statutory purposes set out in the Regulations
This sanctions regime is aimed at:
- encouraging the Iranian Government to comply with relevant UN obligations and abandon nuclear weapons programmes
- restricting the ability of Iran to develop nuclear weapons delivery systems
Import prohibitions
The import prohibitions specified in the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019 are set out as follows:
Regulations 28 to 31C
Regulations 28 to 31 prohibit the import, supply and delivery, acquisition and transfer of certain goods and technology. These cover goods that are consigned from, are located in or originate in Iran , as applicable under the relevant regulation
Regulations 31A to 31C prohibit the provision of technical assistance, financial services and funds and brokering services relating to the import, supply and delivery, acquisition and transfer of certain goods and technology.
Regulations 31D to 31I
Regulations 31D to 31F prohibit the import, acquisition and supply and delivery of gold, precious metals and diamonds. These cover goods that are consigned from, are located in or originate in Iran , as applicable under the relevant regulation.
Regulations 31G to 31I prohibit the provision of technical assistance, financial services and funds and brokering services relating to the import, acquisition, and supply and delivery of gold, precious metals, and diamonds.
Regulation 31J to 31O
Regulations 31J to 31L prohibit the import, acquisition, and supply and delivery, of oil and petroleum products. These cover goods that are consigned from, are located in or originate in Iran, as applicable under the relevant regulation.
Regulations 31M to 31O prohibit the provision of technical assistance, financial services and funds and brokering services relating to the import, acquisition, and supply and delivery of oil and petroleum products.
Regulation 31P to 31U
Regulations 31P to 31R prohibit the import, acquisition and supply and delivery, of petrochemicals. These cover goods that are consigned from, are located in or originate in Iran, as applicable under the relevant regulation.
Regulations 31S to 31U prohibit the provision of technical assistance, financial services and funds and brokering services relating to the import, acquisition, and supply and delivery of petrochemicals.
Regulation 31V to 31Z1
Regulations 31V to 31X prohibit the import, acquisition and supply and delivery of natural gas. These cover goods that are consigned from, are located in or originate in Iran, as applicable under the relevant regulation.
Regulations 31Y to 31Z1 prohibit the provision of technical assistance, financial services and funds and brokering services relating to the import, acquisition, and supply and delivery of natural gas.
Exceptions
Part 6 of the regulations also sets out exceptions to some of the import prohibitions which apply within certain defined circumstances. An exception applies automatically and does not require you to obtain a licence issued in accordance with the Regulations. Exceptions specified in the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019 are set out below:
Regulation 37B
Regulation 37B provides an exception to the prohibitions listed above relating to gold, precious metals and diamonds, oil and petroleum products, petrochemicals and natural gas. The exception applies in relation to any act done by a person where they provide justification to the Secretary of State within the relevant period that the act is an act dealing with an emergency.
Regulation 37E
Regulation 37E provides an exception to the prohibitions on the import, acquisition, and supply and delivery of oil and petroleum products, petrochemicals, and natural gas, and the related prohibitions on technical assistance, financial services and funds and brokering services. The exception applies in relation to any relevant activity which is necessary for the official purposes of a diplomatic mission or consular post in Iran, or an international organisation enjoying immunities in accordance with international law.
Regulation 37F
Regulation 37F(1) provides an exception to the prohibitions on the acquisition of gold, precious metals and diamonds, oil and petroleum products, petrochemicals, and natural gas, and related prohibitions on technical assistance, financial services and funds, and brokering services. This exception applies where those goods are located in the United Kingdom or the Isle of Man, having been lawfully imported there.
Regulation 37F(2) provides an exception to the prohibitions on the acquisition of oil and petroleum products and petrochemicals, and related prohibitions on technical assistance, financial services and funds, and brokering services. This exception applies where a United Kingdom national located in Iran engages in these activities in relation to goods which are located in Iran and are for the personal use of that United Kingdom national or their immediate family members.
Regulation 38
The prohibitions mentioned above do not apply if the act is one which a “responsible officer” (for example, a government or agency official) has determined would be in the interests of national security, or the prevention or detection of serious crime in the United Kingdom or elsewhere.
Trade sanctions licences
A licence is a written authorisation that permits an otherwise prohibited activity. See guidance on how to apply for a trade sanctions licence for information on the types of trade sanctions licences available.
Note that it is for the trader to carry out their own due diligence, determining any relevant controls or actions they may need to take, including obtaining the correct licence. If you are unclear about your obligations or responsibilities, you are advised to seek independent legal advice.
Import licences
BIST’s Import Controls and Sanctions Team is responsible for administering the licensing provisions on behalf of the Secretary of State for all trade sanctions licence applications from importers.
Where traders are looking to import prohibited goods, and where an exception does not apply, you will need to apply for an import licence. If you do not already have an account, you will need to create a GOV.UK One Login account. Once logged in, submit an importer access request and, under ‘What are you importing and where are you importing it from’, also state that you wish to apply for a Sanctions and ad hoc Licence, include your 12-digit EORI number and the relevant commodity codes associated with your import.
Once the importer access request has been approved, you will be able to submit your licence application. We will then consider each application on a case-by-case basis to determine whether granting a licence would be consistent with the stated purposes of the sanctions regime and any UN or other relevant international law obligations.
For certain prohibitions there are some specific activities that we consider likely to be consistent with the aims of the sanctions regime. These are set out below and in further detail in the statutory guidance. If you think that your proposed activity falls within one of these specific descriptions, you should make this clear and explain why you believe this to be the case in your application for a licence. The Secretary of State for Business and Trade is ultimately responsible for decisions to grant or refuse a trade sanctions licence in any individual case.
For further instructions, contact importsanctions@businessandtrade.gov.uk in the first instance, with details of your proposed import.
You should not assume that a licence will be granted or engage in any activities prohibited by trade sanctions until your licence has been granted. If you are unclear on any aspect of the regulations and in what cases a trade sanctions licence is required, we recommend that you seek independent legal advice in the first instance.
Licences granted will not permit activity in respect of Northern Ireland that is not consistent with EU sanctions regulations as they apply via the Windsor Framework.[footnote 1] You will also have to comply with any other licensing requirements under UK import control legislation as applicable.
Considerations for licensing
In line with the requirements of the Northern Ireland Protocol, licences are not required for imports or exports of non-military goods covered by sanctions between Northern Ireland and EU Member States. Licences will however be required from the relevant EU Member State to move items to or from the sanctioned country. You will also have to comply with any other licensing requirements under UK import or export control legislation as applicable.
Import of Oil and Petroleum Products
Bunkering
Vessels entering UK ports are not required to verify the origin of the bunker fuel, as long as the bunker fuel is required for the operation of the vessel pursuing the voyage.
Similarly, aircraft operating a flight between a third country and the UK are not required to verify the origin of the fuel transported in its fuel tank(s) provided the fuel is used only for the flight of the aircraft.
Tank Heels
When a container has previously been used to transport or store Iranian oil or petroleum products, an unpumpable quantity of substance, ‘tank heel’, may remain at the base of the container and cannot be removed without causing damage to the container. If non-Iranian oil or petroleum products are added to the container, it will mix with the tank heel.
The products held in the tank or products processed from such products would not be prohibited from import into the UK under the Iran Regulations.
Co-mingling
Other than in relation to the situations set out in accompanying guidance on tank heels, the prohibitions apply to oil and petroleum products of Iranian origin co-mingled with oil or petroleum products of another origin.
Enforcement of trade sanctions
The Customs and Excise Management Act 1979 (CEMA) makes it a criminal offence to contravene the import sanctions. Some breaches of the import sanctions are triable either way and carry a maximum sentence of 14 years’ indictment or a fine (or both). Any breach of the trade licensing provisions or information requirements in connection with general trade licences is also triable either way and carries a maximum sentence on indictment of 2 years’ imprisonment or a fine (or both). HM Revenue and Customs (HMRC) is responsible for enforcing the licensing restrictions and investigating suspected offences.
If you discover that you have breached any of the trade prohibitions or licensing provisions, you should report the irregularity to HMRC (sometimes known as ‘voluntary disclosure’) as soon as possible.
Enquiries
For further information on import sanctions, contact importsanctions@businessandtrade.gov.uk.
For information on export controls:
- contact the Export Control Joint Unit (ECJU) on 020 7215 4594
- email exportcontrol.help@businessandtrade.gov.uk
- subscribe to the ECJU’s notices to exporters
If your query is related to trade sanctions, contact otsi@businessandtrade.gov.uk.
This document is for information purposes only and has no force in law. Note that where legal advice is required, importers should make their own arrangements.
- ‘Windsor Framework’ has the same meaning as in Joint Declaration No.1/2023 of the EU and the United Kingdom in the Withdrawal Agreement Joint Committee of 24 March 2023.