On 11 December 2023, the UK government issued a new General Trade Licence (GBSAN0001) which provides welcomed clarity and cut off dates on listed iron and steel products that have been processed / manufactured before a certain date. 

Previously, there was no such cut off date such that, taken to the extreme, it could mean that if a listed iron and steel product was manufactured in 2020 (or any time for that matter), and it incorporated a listed iron and steel product of Russian origin, that would be caught under the Chapter 4CA of the UK Russia (Sanctions) (EU Exit) Regulations 2019 (as amended). 

The publication note can be found at gov.uk.