Notice

Guidance on third country processed Russian synthetic diamonds measures

Updated 24 April 2025

This section explains the scope of the measures related to relevant Russian synthetic diamonds processed in third countries only, and the evidence traders need to provide to demonstrate compliance. It does not discuss other prohibitions (including other measures related to Russian diamonds). See the statutory guidance on Russia sanctions for this.

In response to Russia鈥檚 invasion of Ukraine, the UK government has imposed a range of sanctions measures, including trade, financial, transport and other sanctions, under (鈥榯he Russia Regulations鈥). 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.

amended the Russia Regulations and introduced a prohibition on the import of certain Russian synthetic diamonds processed in a third country or multiple third countries. This built on measures banning the import of Russian natural diamonds processed in a third country or multiple third countries, which came into force for diamonds of equal to or larger than 1 carat (0.2g) from 1 March 2024 and for diamonds of equal to or larger than 0.5 carats (0.1g) from 1 September 2024.

The ban on third country processed Russian synthetic diamonds is set out in regulations 46Z16V and 46Z16W, inserted as part of Chapter 4JD into Part 5 of the Russia Regulations by the 2025 Regulations. Third country processing can be a means of concealing the Russian origin of synthetic diamonds, and this measure is targeted at reducing circumvention of sanctions on Russian diamonds.

The prohibition on the import of Russian synthetic diamonds processed in a third country was introduced, and came into effect, on 24 April聽2025 for relevant diamonds equal to or larger than 0.5 carats in weight (0.1 grams or equivalent).

Explanation of regulations聽

For the purpose of this sanction, a relevant processed synthetic diamond is defined in regulation 46Z16V of Chapter 4JD of the Russia Regulations. The HS codes for the relevant products are set out at the end of this guidance.

The regulations prohibit the import into the UK of any synthetic diamond which meets all of the following criteria:

  • is equal to or larger than 0.5 carats (0.1 grams, or equivalent)
  • falls within commodity codes 7104 21, 7104 91
  • was manufactured in Russia
  • has been 鈥榓ltered, transformed in any way, or subjected to any other type of operation or process鈥 in a third country. 鈥楾hird country鈥 means any country that is not the UK, the Isle of Man or Russia (see regulation 46Z16V)

The following scenarios provide examples of how these 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聽

A diamond that is a good listed in regulation 46Z16V of Chapter 4JD when it leaves Russia is then processed in a third country into another good listed in regulation 46Z16V. Importing this product into the UK is prohibited.

For example, unworked or simply sawn synthetic or reconstructed diamonds (HS 7104 21) manufactured in Russia are exported from Russia and enter Country X. Here they are transformed into polished synthetic diamonds (HS 7104 91) and are now of Country X鈥檚 origin before being imported into the UK as synthetic diamonds larger than or equal to 0.5 carats, or equivalent, from 24 April 2025.

The import in this example would be prohibited.

Scenario 2聽

A synthetic diamond manufactured in Russia that is a good listed in regulation 46Z16V when it leaves Russia then undergoes multiple stages of processing in one or more third countries, such that it loses its Russian origin but remains a good listed in regulation 46Z16V. Importing the product into the UK is prohibited because it is a regulation 46Z16V good that was manufactured in Russia.

For example, unworked or simply sawn synthetic or reconstructed diamonds (HS 7104 21) manufactured in Russia are exported from Russia and enter Country X. Here, they are transformed into jewellery incorporating diamonds (ex 7113), such that they are now of Country X origin. These enter Country Y, where they undergo processing removing them from jewellery turning them back into loose polished synthetic diamonds (HS 7104 91), before being imported into the UK. These loose polished synthetic stones are each larger than or equal to 0.5 carats, or equivalent, from 24 April 2025.

The import in this example would be prohibited.

Scenario 3聽

A product manufactured in Russia that is a good listed in regulation 46Z16V of Chapter 4JD when it leaves Russia is then processed in a third country into an entirely different product (a good not listed in regulation 46Z16V). Importing this into the UK is not prohibited under the Russia Regulations.

For example, unworked or simply sawn synthetic or reconstructed diamonds (HS 7104 21) manufactured in Russia are exported from Russia and enter Country X. Here, they are used to manufacture jewellery incorporating diamonds (ex 7113), which is now considered to be of country X origin and is imported into the UK.

The import in this example would not be prohibited under the Russia Regulations.

Guidance on demonstrating compliance聽

Demonstrating supply chain history聽

Traders should be prepared to provide documentation to demonstrate evidence of a good鈥檚 supply chain, which must be consistent with the prohibitions under the regulations.

Evidence requested to be provided through documentation could include:

  • the individual weight of the synthetic diamonds within the package if any stone is larger than or equal to 0.5 carats (0.1 grams or equivalent)

If the package contains diamonds larger than or equal to 0.5 carats (or equivalent) from 24 April 2025, then other evidence requested to be provided through documentation could include:

  • the country of manufacture of the synthetic diamonds processed in the third country (or third countries)
  • the date that the synthetic diamonds left their country of manufacture
  • the country(s) and facility(s) where processing has taken place

An example of evidence may include, but is not limited to:

  • an invoice
  • a certificate of origin issued by a chamber of commerce
  • a bill of lading
  • a diamond origin report or other book or document relating to the goods
  • additional evidence that there is no Russian content, including of the types listed in this guidance

This is not an exhaustive list, but evidence must be verifiable.

A supplier attestation of compliance with this sanction may be acceptable. However, importers should be prepared to provide further evidence retrospectively if required, including to demonstrate that the goods were not manufactured in Russia or are not above the weight limit.

The supplier attestation could take the form of the following wording:

鈥淚 hereby declare that the non-industrial, synthetic diamonds in this shipment were not manufactured wholly or in part in the Russian Federation, notwithstanding whether such diamonds have been substantially transformed into other products outside of the Russian Federation鈥.

Licensing provisions聽

Traders seeking to import banned Russian synthetic diamonds processed in a third country into the UK after 24 April 2025 can apply for an individual 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 DBT considers are likely to be consistent with the aims of the sanctions, and thus may be eligible for a licence. These are set out in the statutory guidance on Russia sanctions.

A licence may be granted for the import of certain Russian synthetic diamonds, processed in third countries, if it relates to the execution of obligations arising from contracts concluded before 24 April 2025.

General Trade Licence聽

The General Trade Licence for sanctioned synthetic diamonds permits the import into the UK of certain diamonds that:

  • were outside of Russia since before 24 April 2025 and then processed outside of Russia before being imported into the United Kingdom

Alongside the import of these goods, the licence permits the provision of certain services and actions related to their import. It may also be used in cases where a trader is unaware of a good鈥檚 origin, such that their goods are potentially prohibited, but can evidence that they have been outside of Russia since 24 April 2025. The licence has a record-keeping requirement, and the category above is subject to individual conditions.

The General Trade Licence will be kept under review. The Secretary of State has the power to vary, revoke or suspend this licence at any time.

Goods outside of Russia before 24 April 2025

The licence permits the import of a prohibited relevant third country processed synthetic diamond that meets both of the following conditions:

  • the synthetic diamond processed to produce the relevant processed synthetic diamond has been located outside of Russia since before 24 April 2025
  • the relevant processed synthetic diamond has been located outside of Russia since before 24 April 2025

Traders should be prepared to have documentation available to demonstrate evidence of a processed synthetic diamond鈥檚 location before the relevant date. This does not need to demonstrate the precise date of manufacture itself, but that the goods existed and were located outside of Russia before that date. Examples of evidence could include an invoice, bill of lading or sales contract. This is not an exhaustive list, but evidence must be verifiable.

Record keeping聽

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)
  • 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 records.importlicences@businessandtrade.gov.uk. Traders should update the details if there are changes by emailing the same address.

Making a customs declaration using this licence聽

Use of this licence entails a customs declaration, using code 9042 and licence number GBSAN0003. Traders cannot use a Declaration by Conduct or an oral declaration to import controlled goods (including sanctioned goods).

Monitoring and enforcement聽

Traders may be requested to present evidence of a good鈥檚 supply chain at the border. In some cases, Customs may require further information relating to the goods to be produced.

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

We advise all parts of the supply chain for third country processed synthetic diamond 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.

Importers are also advised to include assurances that imports are not of Russian origin in contractual agreements.

Note the General Trade Licence will be kept under review, including in response to ongoing monitoring of trade flows and trade practices. The Secretary of State has the power to vary, revoke or suspend this licence at any time.

This page will be updated accordingly with any future amendments.

HS codes in scope for the UK鈥檚 import ban on Russian diamonds processed in a third country聽

Refer to Chapter 7104 of the for more information on the HS codes listed.

HS Code Description
7104 21 synthetic or reconstructed diamonds, unworked or simply sawn or roughly shaped
7104 91 synthetic or reconstructed diamonds, other than unworked or simply sawn or roughly shaped