New UK trade restrictions on Iran take effect from 29 September

29 September 2026

 

UK businesses trading internationally need to be aware of new and expanded trade restrictions on Iran which take effect from 29 September 2026.

The measures significantly broaden the range of goods, technology, services and commercial activities subject to UK sanctions, introducing new restrictions across sectors including energy, metals, maritime, natural gas, oil, petrochemicals and technology.

Crucially, the restrictions are not limited to businesses exporting goods directly from the UK to Iran. They can also apply to third-country trade, indirect supply and delivery, technology transfers and services associated with restricted goods and activities.

For UK importers, exporters and businesses operating international supply chains, this makes checking the destination, end use, customers and nature of a transaction increasingly important.

What has changed?

The Iran (Sanctions) (Amendment) Regulations 2026 strengthen and expand the UK's existing sanctions regimes relating to Iran.

The changes introduce additional trade, financial and transport restrictions alongside nine new schedules – Schedules 1A to 1I – defining categories of controlled goods and technology.

The new trade restrictions cover:

  • Energy-related goods and technology

  • Gold, precious metals and diamonds

  • Graphite and relevant metals

  • Maritime goods and technology

  • Natural gas

  • Oil and petroleum products

  • Other restricted goods and technology

  • Petrochemicals

  • Sectoral software and technology

Businesses dealing in these areas should establish whether their goods, software or technology fall within the relevant schedules before proceeding with a transaction.

For full details of the new measures and controlled goods schedules, see the Government's Notice to Exporters 2026/18.

The measures are not limited to the goods themselves. Depending on the goods, technology and activity involved, restrictions can also apply to supplying or delivering goods, third-country trade, technology transfers, technical assistance, brokering, financial services, insurance and other services associated with restricted transactions.

Iran does not have to be the immediate destination

One particularly important point for exporters is the treatment of the ultimate destination and end use of goods.

UK statutory guidance makes clear that certain restrictions apply to goods exported to Iran as well as goods exported for use in Iran.

As a result, an export restriction may still apply even where Iran is not the immediate destination.

For example, a UK business exporting goods to a customer or intermediary in another country may still need to consider the Iran sanctions regime if it knows, or has reason to believe, that the goods could ultimately be used in Iran.

The restrictions also cover certain direct or indirect supplies and deliveries from a third country to Iran.

This makes effective customer, destination and end-use due diligence particularly important for businesses operating through distributors, intermediaries or complex international supply chains.

Businesses can find further information in the Government's Iran sanctions statutory guidance. 

Shipping and maritime services

The measures also strengthen restrictions affecting shipping and maritime activity.

The UK has powers to specify ships and impose restrictions relating to their operation and associated services.

Services relating to specified ships can include brokering services, chartering services, crew services, financial services or funds, operating services and technical assistance.

Restrictions can also apply to services connected with the acquisition, sale, transfer or supply of a specified ship.

Additional measures can restrict port access and allow vessels to be detained where the relevant legal requirements are met.

For businesses involved in international logistics, freight, shipping, vessel chartering or maritime services, sanctions screening should therefore extend beyond the goods being transported to the vessels and parties involved in the transaction.

Aviation restrictions

The strengthened transport regime also affects aviation.

Under the new measures, certain Iranian aircraft used exclusively for air cargo services are prohibited from landing in the UK, subject to limited exceptions.

Businesses involved in freight forwarding, aviation services and international logistics should therefore consider whether the new transport restrictions have implications for their operations.

Nuclear-related goods and technology

The amendments also strengthen existing controls relating to nuclear goods and technology.

Definitions of nuclear-list goods and technology have been updated in line with relevant International Atomic Energy Agency lists, while the range of dual-use items covered by the restrictions has been expanded.

Restrictions can extend to associated technical assistance, financial services, brokering services and indirect and third-country activity.

Businesses should also be aware that the UK's Iran sanctions framework comprises overlapping regimes. Activities involving restricted goods, technology or services may therefore need to be considered against both the Iran sanctions regulations and the separate nuclear sanctions regime.

Existing restrictions also remain relevant

The latest measures sit alongside existing UK restrictions concerning Iran.

These include controls relating to:

  • Goods and technology that could be used for internal repression

  • Interception and monitoring goods and technology

  • Interception and monitoring services

  • Goods and technology of strategic concern

  • Certain goods associated with Iran's unmanned aerial vehicle and missile programmes

Businesses should therefore avoid treating the new Schedules 1A to 1I as a complete checklist of every Iran-related trade restriction that may apply.

What should UK businesses do?

Businesses trading internationally should review their exposure to the new measures, even where they do not trade directly with Iran.

Key checks should include:

  • Confirm the correct commodity classification of goods

  • Check whether goods or technology fall within Schedules 1A to 1I or other existing controlled categories

  • Screen customers, suppliers and other parties involved in transactions

  • Check the ultimate destination and intended end use of goods

  • Review transactions involving distributors and intermediaries in third countries

  • Consider whether associated services, financing, insurance or brokering activities are restricted

  • Check vessels and other parties involved in maritime transactions where relevant

  • Establish whether an activity is prohibited or whether a licence may be available

  • Keep appropriate evidence of due diligence and compliance checks

Businesses should not assume that a transaction falls outside the restrictions simply because goods are being shipped to a country other than Iran.

Where there is uncertainty over the ultimate destination, end user or intended use of goods, further checks may be necessary before proceeding.

Are licences and exceptions available?

Some activities that would otherwise be prohibited may qualify for a statutory exception or may be permitted under a licence.

The availability of an exception or licence depends on the particular goods, technology, service and circumstances involved.

Licensing responsibilities can also vary depending on the activity and whether goods are subject to strategic export controls.

Businesses should therefore establish the applicable restrictions and licensing requirements before entering into or completing a potentially affected transaction.

What does this mean for UK importers and exporters?

The changes demonstrate why sanctions compliance increasingly needs to form part of wider international trade due diligence.

For exporters, understanding where goods are ultimately going and how they will be used can be just as important as knowing the immediate customer.

For importers and businesses involved in international supply chains, restrictions can also affect goods originating in or consigned from Iran, associated services and other parties involved in a transaction.

With the expanded measures taking effect from 29 September 2026, businesses with potential exposure should review their transactions, supply chains and compliance procedures to ensure they understand whether the new restrictions apply.

 

By Carla Assunção, Chamber International

 

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