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      UK Sanctions on Russian Birch Plywood
      Robert Port • Jun 06, 2023

      Last Updated: 8th November 2023


      Sanctions against Russia are far reaching and so finding the specific legislation relating to birch plywood can be difficult.

      Below I have linked to the specific pages on the UK government website, plus other relevant links to timber trade organisations and environmental bodies.

      Overview

      • The UK and EU have placed import sanctions on Russian Plywood along with many other "revenue generating goods."
      • It is illegal to import Russian plywood & timber products into the UK or EU, either directly from Russia or via another country.
      • Enforcement: may be subject to a fine or prison sentence. See "enforcement of trade sanctions" section below.
      • SPP offers legal alternatives, such as European Birch Plywood and alternative species from legal sources.


      Applicable Regulation 

      "The Russia (Sanctions) (EU Exit) Regulations 2019" specified under Schedule 3DA, Regulations 46XA to 46XG


      Regulation 46XA to 46XG

      Source: https://www.gov.uk/government/publications/notice-to-importers-2953-russia-import-sanctions/nti-2953-russia-import-sanctions#enforcement-of-trade-sanctions


      "Regulation 46XA defines anything specified in Schedule 3DA of the Russia Sanctions Regulations as Schedule 3DA revenue generating goods.


      Regulations 46XB and 46XC prohibit the import and acquisition of Schedule 3DA revenue generating goods. These cover goods that are consigned from, located in, or originate in Russia, as applicable under the relevant regulation. This means that even if the immediate place the goods were shipped from was not Russia, the prohibition may still apply. Regulation 46XD prohibits the supply and delivery, directly or indirectly, of Schedule 3DA revenue generating goods originating or located in Russia to a third country."



      Schedule 3DA

      Source: https://www.legislation.gov.uk/uksi/2019/855/schedule/3DA


      The scope of products is very broad and includes most wood based products listed under various commodity code prefixes.


      Included in the list is 4412 for "Plywood, veneered panels and similar laminated wood."

      Search the page (Ctrl + F) or scroll to find 4412 in the Commodity Code column.


      You can see what is covered within commodity code 4412 by using this link:

      https://www.trade-tariff.service.gov.uk/headings/4412


      Birch Plywood commodity code is 4412 3310 00 (or sometimes written without spaces as 4412331000)

      Source: https://www.trade-tariff.service.gov.uk/commodities/4412331000



      Enforcement of trade sanctions

      Source:

      https://www.gov.uk/government/publications/notice-to-importers-2953-russia-import-sanctions/nti-2953-russia-import-sanctions#enforcement-of-trade-sanctions


      "The Customs and Excise Management Act 1979 (CEMA) makes it a criminal offence to contravene the trade sanctions. Some breaches of the import sanctions prohibitions are triable either way and carry a maximum sentence on indictment of 7 years’ imprisonment or a fine (or both). Under regulation 80 of the Russia (Sanctions) (EU Exit) Regulations 2019, this maximum sentence has been modified to 10 years’ imprisonment. 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). Please refer to part 4 of the CEMA for further details.

      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."


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