UK mirrors EU segregation rules in 'refining loophole' ban

The UK will mirror EU enforcement guidelines for its 'refining loophole' ban on fuels made from Russian oil in third countries, offering flexibility for refiners that can separate their crude streams and exemptions for net exporters.

The new import ban came into force on May 20, seven months after it was first announced by the government in October, but exempted diesel and jet fuel, the UK's two largest oil product imports.

New sanctions will outlaw imports of refined products like gasoline, naphtha and waste oils derived from Russian crude, as well and paraffin and lubricants, the foreign ministry said.

Special licenses for diesel and jet fuel were issued on an indefinite basis due to concerns over associated costs to businesses, and the Secretary of State aims to give four months' notice before revoking the waiver, according to guidance from the department of Business and Trade.

Much like the EU's guidance on its equivalent import ban, which took effect in January, the UK will continue to allow some fuel to arrive from refiners that buy Russian crude, provided that they can meet one of two provisions.

In the first case, refiners can send fuels to the UK if they have infrastructure to prevent Russian and non-Russian oil from mixing at any time, including in the terminals, pipelines and processing units. In the EU case, a similar carve-out has allowed India's Jamnagar refinery to continue sending fuel into the bloc, after committing to exclusively refine non-Russian crude in one of two refineries at the site.

In cases where refiners cannot physically segregate their feedstocks, importers must be able to demonstrate that the supplier did not receive or process Russian oil for at least 60 days. The guidelines advise all UK buyers to include assurances that imports are not produced using Russian crude oil in contractual agreements, through attestations or further evidence if required.

Country-level exemptions

The stricter import laws are expected to target refiners in countries like India and Turkey, some of Russia's top crude buyers and recently key suppliers into Europe. Jurisdictions that have issued their own sanctions on Russian crude oil, including the EU, Canada, Norway, USA, Switzerland, Australia, and New Zealand, will not be required to demonstrate compliance.

Also in line with the EU guidelines, the UK will exempt net oil exporters from having to prove compliance, unless UK customs officials have "reasonable grounds to believe" their exports were not made from locally-produced crude.

Using trade data from the International Energy Agency, 63 countries were classed as net exporters exempted from stricter oversight, including Saudi Arabia, Kuwait, Kazakhstan, Libya and Nigeria. In contrast, the EU guidelines included a longer list of 81 countries, which included Venezuela as well as smaller exporters like Burundi, Gambia and Burkina Faso.

Vessels entering UK ports will not be obliged to verify the origin of their bunker fuels, nor will international aircraft be expected to demonstrate the source of their jet fuel.

In practice, the UK has recently imported limited supplies from countries like India and Turkey, and those flows are protected by the waiver for diesel and jet fuel. According to S&P Global Commodities at Sea data, the UK imported 32,000 b/d of Indian jet/kerosene and 7,000 b/d of gasoil in 2025, and no other oil products.

Supplies have fallen to zero since January, when the war in Iran saw product rerouted to geographies like East Africa and Southeast Asia. Trade flows from Turkey have proven even scarcer, with no product arriving in the UK since Feb 2024. Instead, the UK has increasingly relied on the US for its fuel in recent months. According to CAS data, the US shipped 144,000 b/d of oil products to the UK in April, of which 90% were jet fuel or diesel, accounting for almost half of total imports.

Based on analysis from S&P Global Energy CERA, the UK has imported roughly 75% of its jet fuel and 50% of its diesel in 2025, including large volumes from Middle Eastern countries like Kuwait.