Implementation notifications on the UK steel trade measure
Background
On 19 March 2026, the Secretary of State for Business and Trade announced a new steel trade measure to preserve vital steel production for critical national infrastructure and defence. This follows the expiry of the existing steel safeguard quotas and the 25% additional safeguard duty after 30 June 2026.
The new measure came into effect on 1 July 2026, and includes a 50% out-of-quota duty (described as ‘Third-country duty’ on the UK’s Online Tariff Tool) which applies on relevant product lines.
More information on the measure can be found in the UK’s steel trade measure from 1 July 2026 decision, updated on 25 June 2026.
Transitional exemption eligibility
For the new steel trade measure, a time-limited transitional arrangement is available. Under this arrangement, relevant goods under contract before 14 March 2026 are fully exempt from the 50% out-of-quota duty when imported between 1 July 2026 and 30 September 2026.
This means that the tariff associated with this new measure does not apply to goods:
- imported into the United Kingdom between 1 July 2026 and 30 September 2026, and
- imported in satisfaction of an obligation under a contract entered into before 14 March 2026
Goods released to the UK market from a customs warehouse between 1 July 2026 and 30 September 2026 can make use of this exemption if they were imported to the UK in satisfaction of an obligation under a contract entered into before 14 March 2026.
Goods that make use of this transitional exemption will not count towards quota allocations for quarter 1 (1 July 2026 to 30 September 2026).
Evidencing eligibility of goods for the transnational exemption
To use this exemption, traders must hold verifiable evidence demonstrating that the consignment was ordered before the cut-off date.
This may include, but is not limited to:
- written contracts (including sales contracts)
- invoices
- proofs of payment
- customs warehousing records
When claiming the exemption, HM Revenue and Customs (HMRC) will expect steel importers to hold evidence that the relevant import is eligible for the transitional exemption and may request evidence of this even after the goods have been released.
Traders must retain and provide evidence on request. HMRC will take appropriate enforcement action where cases of non-compliance or deliberate fraud are detected.
Instructions for declaring on the Customs Declaration Service (CDS) to claim the exemption
When declaring goods in scope of the measure using the Customs Declaration Service (CDS), use document code 9Y16 in Data Element 2/3, along with Preference Code 100 in Data Element 4/17, to confirm that the eligibility requirements are met.
Only use this code if you hold the required evidence. A quota order number should not be entered on the declaration in this scenario. Goods declared under this code 9Y16 will not count towards quota usage.
Quota administration
The right to access quotas is granted by HMRC to importers in the UK on a ‘first come, first served’ basis.
Importers are asked to cite the relevant order number set out in Table 4 of the ‘UK’s steel trade measure from 1 July 2026’ attachment, and as specified on the online tariff tool, when applying to HMRC to access a particular quota.
Quotas will be designated as critical when HMRC give notice that 90% of each quarterly volume has been allocated. This is as per the public notice made under the Customs (Tariff Quotas) (EU Exit) Regulations 2020.
You will have to provide for the full amount of duty if the quota is critical as your claim may be refused. You can provide this security using a general guarantee account. View further information on how to apply for a general guarantee account.
Unused quota volume carryover
Unused quota volumes, whether country-specific or residual, will carry over into the following quarter within the same quota year. Carryover will take effect on the 20th working day following the end of the relevant quarter.
Unused quota volumes may accumulate across quarters within the same quota year. Any quota volume remaining at the end of the quota year will lapse and will not be carried forward.
Unused quota volume carryover will not apply to Category 1 authorised use products.
Limited access to unused quota following the end of each quarter within a quota year
Claims to access the previous quarterly quotas will be available up to the end of the 19th working day of the month following the end of quarters 1 to 3.
Any balance remaining at the end of quarter 4 will be available for importers to claim up to 3 years after the goods were imported.
Inward processing and freeports
Steel that is in scope of the new measure can be placed under the inward processing or freeport customs special procedure. These procedures remain available for processing and, in the case of freeports, both processing and storage of steel products with import duties suspended.
Where the processed steel is subsequently released to free circulation in the UK, from 1 July 2026, import duties will be calculated based on the steel as it was when declared into the inward processing or freeport customs special procedure, rather than the processed product. This ensures that the measure cannot be circumvented through processing.
No import duty will be payable where goods are processed and exported directly from the UK, provided they are not re-imported into the UK within 12 months.
Goods imported into a storage procedure and subsequently released to free circulation are also subject to the new steel measure.
Ukraine exclusion
The new measure does not apply to steel goods originating in Ukraine reflecting the UK’s continued support in light of Russia’s ongoing invasion. Instead, existing preferential tariff arrangements for UK-Ukraine trade in steel remains in place, as set out in the Political, Free Trade and Strategic Partnership Agreement with Ukraine.
Access to preferential rates is subject to compliance with preferential rules of origin set out in the agreement. For further details, read the guidance on Trade with Ukraine.
Trade remedies
The UK continues to operate a trade remedies framework in line with World Trade Organization (WTO) rules as part of its wider trade defence toolkit. Trade remedies are targeted duties applied to imports where there is evidence of unfair trade practices (dumping or subsidisation), or sudden surges of imports.
View dumping, subsidisation and safeguarding investigations guidance or contact the Trade Remedies Authority (TRA) at contact@traderemedies.gov.uk
The UK currently applies 17 separate anti-dumping and anti-subsidy measures on steel imports, and these remedies will continue to apply alongside the steel trade measure being implemented on 1 July 2026. This means the existing anti-dumping and anti-subsidy duties applies to goods imported within the tariff-free quota.
These duties will cumulate with the steel measure’s 50% out of quota duty once quotas are exhausted. View details of the anti-dumping and anti-subsidy measures currently in force.
The TRA will continue to conduct new dumping and subsidy investigations where they receive evidence-based applications from industry.
Carbon Border Adjustment Mechanism (CBAM)
The UK CBAM is an environmental domestic tax designed to tackle the risk of carbon leakage. It is separate to the steel trade measure – read further information on the UK CBAM.
The UK CBAM will apply from 1 January 2027 alongside the steel trade measure which came into force on 1 July 2026, and in addition to current trade remedy measures.
Ship-work authorised use
Ship-work authorised use relief does not apply to steel products that fall within the scope of the steel measure. This is to prevent circumvention of the application of the steel measure.
Contact
For general queries about customs declarations, you can contact HMRC online, by phone or by post.
For queries about the new steel measure, you can contact the Department for Business and Trade (DBT) by email: tariff.implementation@businessandtrade.gov.uk.
Alternatively, you can contact DBT by telephone: +44 (0)20 4551 0011.