Notice

Guidance on third country processed oil product measures

Updated 19 May 2026

This section explains the scope of the measures related to oil products processed in third countries using Russian crude oil, and the evidence importers need to provide to demonstrate compliance. It does not discuss other prohibitions, including other measures related to Russian oil and oil products. For these, see Russian oil and oil products. For other prohibitions, see the statutory guidance on Russia sanctions. 

In response to Russia’s invasion of Ukraine, the UK government has imposed a range of sanction measures, including trade, financial, transport and other sanctions, under The Russia (Sanctions) (EU Exit) Regulations 2019 (‘the Russia Regulations’). The sanctions are aimed at encouraging Russia to cease actions which destabilise Ukraine, or undermine or threaten the territorial integrity, sovereignty, or independence of Ukraine. 

The Russia Sanctions (EU Exit) (Amendment) Regulations 2026 (‘the 2026 Regulations’) amended the Russia Regulations and introduced, along with several other measures, a prohibition on the import of relevant oil products processed in a third country using Russian crude oil. This built on measures banning the import of Russian origin oil and oil products introduced in 2022, which remain in effect.

Third country processing may allow Russian oil to enter the UK via the ‘back door’, and this measure is targeted at addressing that and further reducing Kremlin revenues. Our approach is aligned with the EU’s to maximise the impact of these measures on Russia. The ban on the import of third country-processed oil products is set out in Regulation 46Z9F, inserted as part of Chapter 4IB into part 5 of the Russia Regulations by the 2026 Regulations.

The prohibition on the import of oil products processed in a third country using Russian crude oil was introduced on 19 May 2026 and came into effect on 20 May 2026. 

Explanation of regulations

The regulations prohibit the import into the UK of an oil product, when it meets both of the following criteria: 

• falls under Harmonized System (HS) code 2710 ‘petroleum oils, preparations, waste oils’ 
• has been processed in a third country from oil or oil products falling under HS code 2709 originating in Russia (termed as ‘crude oil’ throughout this guidance) 

‘Third country’ for these purposes means a country that is not the United Kingdom, the Isle of Man or Russia (see regulation 46Z9E).

The regulations also prohibit UK companies from providing the following, directly or indirectly, relating to the import into the UK of oil products produced in third countries using Russian crude oil:

• technical assistance
• financial services or funds
• brokering services

Tank heel

When a container located in a third country has previously been used to transport or store Russian crude oil, or oil products produced using Russian crude oil, 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-Russian crude oil or oil products produced using non-Russian crude oil 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 Russia Regulations. 

Oil products produced using crude oil that originates in a third country and flows through Russian pipelines

Oil and oil products of non-Russian origin may unavoidably transit through or depart from Russia. The ban is not contravened where an oil product is produced in a third country using crude oil that originates in another third country, is not Russian owned, and has only transited through or departed from Russia. 

For instance, the Caspian Pipeline Consortium (CPC) pipeline transports Kazakh crude oil through Russia and the Kazakh oil is mixed with small volumes of Russian crude oil as a consequence of transportation. The oil cannot be physically segregated once mixed and the crude oil will be certified as Kazakh origin. Our intention is that oil products produced in a third country using this crude oil can be imported into the UK.

Co-mingling

Other than in relation to the situations set out in accompanying guidance on tank heels and transit through a pipeline, the prohibitions apply to oil products produced in a third country from crude oil comprised of Russian oil co-mingled with oil of another origin. The prohibitions also apply to co-mingled oil products comprised of oil products produced in a third country using Russian crude. 

Bunkering

Vessels entering UK ports are not required to verify the origin of the crude oil used for processing 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. 

Scenarios

The following scenarios provide examples of how the rules may be applied in practice (where Country X and Country Y are countries that are not the UK, the Isle of Man, or Russia).

Scenario 1 

A third country imports Russian crude oil falling under HS 2709 and refines it into an oil product falling under HS 2710. Importing this product into the UK is prohibited. 

For example, a refinery in Country X imports Russian crude oil and refines it into jet fuel (HS 2710 1921) before it is imported into the UK. 

The import in this example would be prohibited. 

Scenario 2 

A third country imports co-mingled or blended crude oil falling under HS 2709 that contains some Russian crude oil, and refines it into an oil product falling under HS 2710. Importing this product into the UK is prohibited. 

For example, a storage hub in Country X imports Russian crude oil and co-mingles it with non-Russian crude oil, before exporting it to a refinery in Country Y where it is refined into diesel (HS 2710 1944) and imported into the UK. 

The import in this example would be prohibited.

Scenario 3 

A third country imports Russian crude oil falling under HS 2709 and refines it into an oil product falling under HS 2710. It then exports the oil product to another third country, where it is mixed with oil products produced using non-Russian crude oil. Importing this product into the UK is prohibited. 

For example, a refinery in Country X imports Russian crude oil and refines it into jet fuel (HS 2710 1921) before exporting it to Country Y where it is co-mingled with jet fuel produced using non-Russian crude oil at a storage hub. The jet fuel is imported into the UK. 

The import in this example would be prohibited. 

Scenario 4 

A refinery in a third country, which segregates and processes Russian and non-Russian crude oil separately, refines non-Russian crude oil falling under HS 2709 into an oil product falling under HS 2710. Importing this product into the UK is not prohibited. 

For example, a refinery in Country X imports both Russian and non-Russian crude oil. It segregates and refines the non-Russian crude oil into diesel (HS 2710 1944) and provides evidence demonstrating that the crude oil used to produce the diesel was not Russian. The diesel is imported into the UK. 

The import in this example would not be prohibited. 

Guidance on demonstrating compliance

Importers should be prepared to provide documentation to demonstrate evidence of an oil product’s supply chain at the point of import or retrospectively. The supply chain must be consistent with the prohibitions under the regulations. 

Evidence should demonstrate that an oil product has not been produced using Russian crude oil. Where a refinery can segregate and process Russian crude separately, importers should provide evidence of this. Where a refinery is unable to segregate and process Russian crude separately, importers should provide evidence that no Russian crude has been received or processed by that refinery in the last 60 days. 

Examples of evidence may include supplier or refinery attestations. However, importers should be prepared to provide further evidence retrospectively if required. 

A supplier attestation may take the form of the following wording:

“I hereby declare that the oil products (HS code 2710) in this shipment were not processed or refined wholly or in part from crude oil (HS code 2709) originating in Russia.”

A refinery attestation may take the form of the following wording:

“I hereby declare that the oil products that have been purchased by [COUNTERPARTY] were not processed or refined wholly or in part from crude oil (HS code 2709) originating in Russia.

“Any Russian origin crude oil (HS code 2709) imported or processed was and continues to be segregated from non-Russian origin crude oil (HS code 2709) and processed separately from non-Russian origin crude oil (HS code 2709) by the refinery. The refinery infrastructure (including but not limited to terminals, ports, pipelines, tanks, processing units, transportation on refinery grounds) does not allow commingling at any time between Russian origin crude oil and non-Russian origin crude oil. Additionally, any oil product (HS code 2710) derived from non-Russian origin crude oil (HS code 2709) is segregated from and is not mixed or commingled with refined product derived from Russian origin crude oil (HS code 2709).”

Or

“During the 60 days prior to the bill of lading date for the oil products (HS code 2710) purchased by and to be delivered to [COUNTERPARTY], the refiner did not import or process Russian origin crude oil (HS code 2709) into the refinery that produced the product to be purchased by and delivered to the counterparty.”

The sanctions apply regardless of the importer’s knowledge about the origin of the crude oil used to produce the goods, their location or the place from which they were consigned. If prohibited goods are imported into the UK then it is a breach of the sanctions and is open to enforcement action, including seizure of the goods. 

Breaching these sanctions, or seeking to circumvent them, can also be a criminal offence. Importers must therefore carry out due diligence and take reasonable steps to ensure that oil products have not been produced using Russian crude oil before being imported into the UK. Importers are advised to include assurances that imports are not produced using Russian crude oil in contractual agreements with suppliers. 

Importers should note that regardless of any due diligence or other steps taken, if they are aware that oil products have been produced using Russian crude oil or they have reasonable cause to suspect that this is the case, importing those goods into the UK can be a criminal offence. 

Imports from certain countries

The EU, Canada, Norway, USA, Switzerland, Australia, and New Zealand

In recognition of the European Union, Canada, Norway, USA, Switzerland, Australia, and New Zealand having sanctioned imports of Russian crude oil, importers importing relevant oil products into the UK from these countries will not be required to provide evidence of supply chain history at the point of import to demonstrate compliance with the sanctions. 

Net exporters of crude oil

Imports from countries that are net exporters of crude oil benefit from a presumption that the oil product has been made using crude oil produced in that country and importers will not be required to provide evidence of supply chain history at the point of import, to demonstrate compliance with the sanctions.

In the event HM Revenue and Customs (HMRC) have reasonable grounds to believe that an oil product imported from a net exporter country has not been produced using crude oil originating in that country, they may request further evidence, including retrospectively.

Importers of oil products produced in countries that are net exporters of crude oil are advised to include assurances that imports are not produced using Russian crude oil in contractual agreements with suppliers. The arrangements for countries with sanctions on Russian crude and net exporters of crude have been introduced to facilitate import processes at the border for non-sanctioned oil products. They do not permit the import of sanctioned oil products, unless imported under a licence. 

Note that other customs arrangements continue to apply, including in relation to HMRC checks, inspections, and through requests for documentation and evidence, including retrospectively, once goods have been released. 

Licensing provisions 

Importers seeking to import banned oil products processed in a third country into the UK after 20 May 2026 can apply for a trade sanctions 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.

There are some specific activities that the Department for Business and Trade (DBT) considers are likely to be consistent with the aims of the sanctions and may be eligible for a licence. These are set out in the statutory guidance on Russia sanctions. 

General Trade Licence

The General Trade Licence for sanctioned processed oil products permits the import into the UK of the following prohibited goods processed in third countries from Russian crude oil:

• diesel (HS 2710 19 42 or HS 2710 19 44)
• jet fuel (HS 2710 19 21)

Alongside the import of these goods, the licence permits the provision of certain services and actions related to their import. The licence has a record-keeping requirement.

The Secretary of State for Business and Trade may vary, revoke or suspend the Licence at any time. The Secretary of State will endeavour to provide 4 months’ notice of any decision to revoke this licence.

Record keeping

Regulation 76 of the Russia Regulations sets out a requirement to keep a register or record of each act carried out under the authority of a general trade licence. The regulation sets out which details may be necessary and the length of time records should be kept for.

Traders should notify the Secretary of State for Business and Trade, providing:

• their name (or organisation name)
• Economic Operator Registration and Identification (EORI) number
• the address at which the register or record may be inspected

This must be done no later than 30 days after first acting under the authority of this licence. This only needs to be done once, by emailing importsanctions@businessandtrade.gov.uk. Traders should update the details if there are changes by emailing the same address.

Making a customs declaration using this licence

Traders importing goods under this licence are not required to have documentation available to demonstrate evidence of a good’s supply chain, in order to comply with these sanctions.

Use of this licence entails a customs declaration, using code 9L51 and licence number GBSAN0004. Traders cannot use a seclaration by conduct or an oral declaration to import controlled goods (including sanctioned goods).

Monitoring and enforcement 

HMRC are responsible for enforcing the licensing requirements and investigating suspected offences.

Importers may be requested to present evidence of a good’s supply chain at the border. In some cases, customs may require further information relating to the goods to be produced. 

We advise all parts of the supply chain for third country-processed oil product imports to the UK to undertake the necessary due diligence to ensure that sanctions are not being circumvented directly or indirectly. Not complying with the sanctions could constitute one of a number of criminal offences. See the statutory guidance on Russia sanctions for more information on penalties.

List of net exporter of crude oil countries

• Afghanistan*
• Albania
• Algeria
• Angola
• Antigua and Barbuda*
• Argentina
• Azerbaijan
• Bahamas*
• Barbados*
• Belize*
• Bhutan*
• Brazil
• Cambodia
• Cameroon
• Chad
• Colombia
• Democratic Republic of the Congo
• Dominica*
• Ecuador
• Egypt
• Equatorial Guinea
• Fiji*
• Gabon
• Ghana
• Grenada*
• Guatemala
• Guyana
• Iran
• Iraq
• Kazakhstan
• Kiribati*
• Kuwait
• Libya
• Malawi*
• Maldives*
• Mexico
• Moldova
• Mongolia
• Mozambique
• Myanmar
• Nigeria
• Oman
• Palau*
• Papua New Guinea*
• Qatar
• Republic of Congo
• Saint Kitts and Nevis*
• Saint Lucia*
• Saint Vincent and the Grenadines*
• Samoa*
• Sao Tome and Principe*
• Saudi Arabia
• Solomon Islands*
• South Sudan
• Sudan
• Timor-Leste*
• Tonga*
• Trinidad and Tobago
• Tunisia
• Turkmenistan
• United Arab Emirates
• Vanuatu*

• Venezuela

• countries for which only aggregated data across multiple countries is available 

As the UK government does not compile official data on oil production and trade of other countries, this list is based on data from the International Energy Agency (IEA) – an international organisation of which the UK is a member and a recognised authority on international oil data and energy analysis. 

The primary data source used to compile the list is the IEA’s World Energy Statistics (WES) database. This dataset provides import and export data for crude oil. The WES online data service contains important annual energy statistics for 156 countries and 35 regional aggregates.

For all Organisation for Economic Co-operation and Development (OECD) countries and some larger non-OECD countries 2024 data is available, this was complimented with 2023 data for countries where data for 2024 was not yet available. The table will be updated once a year in order to establish the list based on the previous calendar year.

Where the IEA does not provide data for individual countries (especially smaller nations), these are placed into regional groupings – for example ‘Other Non-OECD Asia and Oceania’, ‘Other Non-OECD Americas’ and ‘Other Non-OECD Africa’. Unless disaggregated data is available, these groupings have been treated in the aggregate.

It is assumed that, if the aggregated group is a net exporter of crude oil, then all countries within it are also net exporters, and vice versa. These countries are denoted with an asterisk (*).