An email seen by Lube Report indicates that U.K. trade remedy duties on certain lubricants may be unenforceable in Northern Ireland because of the unique arrangements governing the U.K.-EU land border.
The U.K. Trade Remedies Authority addressed the issue in response to an Aztec Oils complaint that Mannol products were being sold below cost in Northern Ireland after being imported from Ireland.
A spokesman for the Department for Business and Trade told Lube Report the rules are clear: “Businesses cannot by law use Northern Ireland as a route to avoid UK tariffs, and HMRC conducts checks and can impose penalties on importers, including by seizing and destroying goods, if they do evade duties.”
The Windsor Framework, agreed in the wake of Brexit, preserves an open land border between the U.K. and the European Union on the island of Ireland. Goods moving from the Republic of Ireland into Northern Ireland are not subject to customs inspections at that crossing.
Trade remedy measures, including anti-dumping duties imposed by the U.K. government in December 2025 on lubricant imports from the UAE and Lithuania, are typically collected at the point of import. His Majesty’s Revenue and Customs is responsible for administering and enforcing those duties.
However, because there are no routine customs controls at the Ireland-Northern Ireland land border, authorities cannot collect trade remedy duties at that point. As a result, products imported into the European Union through Ireland without U.K.-imposed duties could subsequently move into Northern Ireland without triggering enforcement at the land border.
The TRA said in the email that there is no payment or enforcement of trade remedies duties at that border with the EU.
The issue was highlighted by Mark Lord, managing director of Aztec, who described the situation as a potential enforcement gap. Lord has spearheaded efforts to press the U.K. government to clamp down on lubricant dumping.
“We were quite frankly shocked to receive this response from the TRA, as we sought clarification after identifying a continuation of dumping in Northern Ireland,” Lord told Lube Report. “We will continue to work closely with the authorities to resolve this issue.”
“The issue of product dumping in Europe is escalating and we would hope that the European authorities will follow the U.K.’s lead in closing down the opportunities for bad actors to damage our industry,” Lord said.