Introduction of new UK trade sanctions against Iran

Introduction

Iran sanctions: Impact on imports

Additional import controls have been introduced across Chapters
27, 28, 29, 31, 39, and 71
.
Iranian-origin crude oil and petroleum products, natural gas, petrochemicals, chemicals, fertilisers, plastics, gold, precious metals, and diamonds are subject to import prohibitions.
The prohibitions bite on the origin or consignment of the goods themselves and are not limited to goods supplied by designated persons. Importers should therefore consider origin and the full consignment route as part of their due diligence, not simply screen counterparties against the UK Sanctions List.
Increased scrutiny applies to transactions involving Iranian exporters, intermediaries, financiers, or shipping companies.
Customs authorities may request evidence demonstrating that products are not linked to sanctioned Iranian activities.
Supply chains involving Iranian raw materials, chemicals, petrochemical derivatives, or precious metals should be reviewed.
Goods indirectly routed through third countries may still be subject to sanctions if an Iranian connection exists.
Shipments suspected of involving sanctioned Iranian goods may face detention, seizure, or refusal of entry.

Iran sanctions: Impact on exports

Export restrictions have been introduced across Chapters
25, 27, 28, 29, 31, 38, 39, 68, 69, 71, 72, 73, 74, 75, 76, 78, 79, 80, 81, 84, 85, and 90
.
Controls now cover a broad range of industrial and strategic goods exported to Iran.
Graphite and raw or semi-finished metals - including iron and steel, copper, aluminium, nickel, lead, zinc, tin, and other base metals such as tungsten, molybdenum, tantalum, and titanium - are subject to export prohibitions.
Industrial machinery, manufacturing equipment, pumps, valves, turbines, machine tools, and engineering products should be checked against Schedules 1A to 1I; goods within the Schedules are prohibited unless a licence is granted or an exception applies.
Electronics, scientific instruments, sensors, telecommunications equipment, and technology products should be checked against Schedules 1A to 1I and may require a licence.
Maritime goods and technology, including marine engines, propulsion equipment, and navigational and surveying instruments, are controlled under Chapters 84, 85, and 90. Restrictions on vessels themselves are imposed through the Regulations, including powers to specify ships and restrict their operation and related services, rather than through tariff measures in Chapter 89.
Chemicals and chemical-processing equipment that could support Iranian industrial activities are restricted.
Review whether goods and technology fall within Schedules 1A to 1I of the 2019 Regulations, which define the scope of restricted goods and technology.
Exporters must assess whether products could contribute to Iran's military, defense, aerospace, maritime, energy, or dual-use capabilities.
Transfers involving sanctioned Iranian organizations, government-linked entities, or designated individuals are prohibited or restricted.
The prohibitions apply unless an exception applies or a licence is granted. Licensing is administered by the Office of Trade Sanctions Implementation (OTSI) and the Export Control Joint Unit (ECJU). A new OTSI general trade licence permitting services necessary for the continued operation of the Shah Deniz gas field in Azerbaijan came into force on 29 September 2026. OFSI also amended an existing general licence to permit certain related financial activities, with effect from 29 September 2026.

Expanded restrictions on Iran-related activities

Supply and delivery of controlled goods and technology (including third-country trade), making goods and technology available, and associated ancillary services.
Technical assistance provided to Iranian entities.
Technology transfers involving Iran.
Supply of sectoral software and associated technology, including enterprise resource planning (ERP), customer relationship management (CRM), business intelligence, supply chain management, and computer-aided design and manufacture (CAD/CAM) software. This covers intangible supply such as downloads, cloud access, and software provided as a service. A wind-down permits pre-existing contractual obligations to be discharged until 7 March 2027.
Financial restrictions targeting persons connected with Iran, including prohibitions on loans, credit and investment, restrictions on banking relationships and market access, and dealings in Iranian sovereign bonds.
Insurance and reinsurance services provided to persons connected with Iran, and related brokering services. Contracts lawfully entered into before 8 September 2026 are carved out.
Maritime transportation and shipping support, including measures directed at specified ships and powers to specify ships and restrict their operation, including port access restrictions and detention, together with additional ship-related prohibitions under the 2023 Regulations.
Activities involving dual-use goods that may support Iran's industrial or military capabilities.
Landing in the UK of Iranian cargo aircraft, subject to limited exceptions for emergencies and non-traffic technical stops.

Impact on trade operations

Identify products that fall within the newly controlled chapters and within Schedules 1A to 1I of the 2019 Regulations.
Screen customers, suppliers, vessels, and financial institutions against Iran sanctions lists.
Review contracts involving Iranian counterparties.
Assess exposure to Iranian-origin materials and components.
Verify end users and end-use activities before export.
Evaluate licensing requirements for controlled products.
Strengthen monitoring of maritime and logistics routes involving Iran.

Conclusion