Steel imports: "melt and pour" traceability

FRIDAY, 11 SEPTEMBER 2026

From 1 October 2026 EU steel importers must prove the country where the product was melted and poured: here is how to adapt documents and procedures.

What changes from 1 October

From 1 October 2026 the new European regime on the traceability of imported steel enters its operational phase. The step is set by implementing regulation (EU) 2026/1963, published on 31 August 2026 and adopted by the Commission after unanimous support from Member States on 19 August. The measure completes the implementation of regulation (EU) 2026/1384 of 17 June 2026, which redesigned the entire framework for steel imports into the Union.

The core of the change is the so-called melt and pour criterion, meaning "melting and pouring". From October importers must be able to demonstrate in which country the iron or crude steel was first produced in liquid form and then poured until reaching its first solid state. What matters is therefore not the country of the last substantial transformation, but the one where the steel product truly originates.

Why the Union chose the melting criterion

By adopting melt and pour, the EU aligns itself with the criterion already in force in the United States. The goal, as experts from Studio Armella e Associati point out, is to strengthen traceability along the entire supply chain and to prevent the last stage of processing from being relocated simply to circumvent duties. The measure aims to counter global excess production capacity and the resulting diversion of trade flows towards the European market.

Let us recall the tariff framework: the new regime provides for zero-duty quotas covering 18.3 million tonnes and a 50% duty on imports beyond the threshold, sharply up from the previous 25%. A detail that makes the correct identification of origin even more relevant in terms of costs.

How to prove origin: documents and transitional regime

In ordinary cases, proof of the place of melting and pouring will come from a certificate issued by the producer. The document must precisely indicate the place of melting, the place of pouring and the heat number of the imported steel. To ease the start-up, the regulation provides for a transitional phase until 30 September 2027.

If the producer's data is incomplete, the customs authority may consider a range of alternative documents already used in normal commercial transactions:

• purchase invoice and delivery note
• quality certificate
• long-term supplier declarations
• commercial correspondence and product description

The rules apply to the 26 categories of steel products identified in Annex 1: finished and semi-finished products classified under certain subheadings of chapters 72 and 73 of the Combined Nomenclature, including flat-rolled products, wire rod and various types of profiles.

What purchasing offices should do now

For importers, the time available to adapt is short. The advice is to immediately map suppliers and product references falling within the affected categories, checking which ones can already issue the melting and pouring certificate with the heat number. Where the producer cannot provide it, it is best to organise now an orderly collection of alternative documents so as not to block customs operations. It is worth updating contractual clauses and documentation requests, so as to include the melt and pour data requirement in future orders. The transitional phase until September 2027 offers some margin, but aligning procedures and customs classifications before 1 October reduces the risk of delays, disputes and higher duties.

With La Merce, importing steel after 1 October means already holding the manufacturer's certificate with the country of melting and casting and the cast number, collected from the supplier before the goods leave: that is the document customs asks for, and retrieving it afterwards is the expensive part.

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