The TRA wrote that imported finished lubricants undercut U.K. sales prices and recommended the application of duties. The authority also recommended importers “obtain a bank guarantee, secure a bond or pay a cash deposit equal to the provisional duty against their customs declaration.” This can be applied to goods for up to six months and extended up to a maximum of nine months, the TRA explained to Lube Report.

“If the Secretary of State accepts our recommendation to impose provisional measures or decides to impose an alternative provisional measure, importers may be asked to provide a guarantee to cover the duty amount they would incur if measures were made final,” it said.

“I was pleased that they were recommending a tariff and were seeking immediate implementation with guarantees of payment,” Mark Lord, CEO of UK lubricant producer Aztec Oils. “It will be interesting to see whether they do this.”

Lord has led efforts to bring the issue to the attention of the authorities. However, Lubriage are confident that the final determination will be different.

“It is my understanding that the recent publication by TRA is based from information that they held at or about September 1, 2024; long before our client’s data (which was extensive) was submitted,” Lubriage’s lawyer said in an email to Lube Report. “It understandably takes time for officials to report, and they have various timescales that they have to meet, but at the same time a balanced view can only be taken once al of the submissions have been considered. That process is ongoing.”

The TRA’s report says information provided by the cooperating importer was limited.