Melt-and-pour evidence rules take effect: the triple compliance stack for EU steel importers

Since October 1, 2026, every import of steel covered by the EU Steel Regulation must arrive with proof of the country where the steel was melted and poured. Implementing Regulation (EU) 2026/1963, published in the Official Journal on August 31, 2026, sets out what that proof looks like: in the first instance a Mill Test Certificate stating the country of melt and pour and the heat number of the imported steel.

The requirement is the third compliance layer to land on EU steel importers within ten months, after the CBAM definitive phase started on January 1, 2026 and the Steel Regulation's quotas and 50 percent out-of-quota tariff began applying on July 1, 2026. Each shipment now runs through three separate regimes with three separate evidence chains.

What the melt-and-pour requirement demands

From October 1, 2026, importers of steel products listed in Annex I of Regulation (EU) 2026/1384 must state the country of melt and pour in the customs declaration and support it with verifiable evidence, primarily a Mill Test Certificate showing that country and the heat number. The country of melt and pour is the country where the raw steel or iron was first produced in liquid form in a steel-making or iron-making furnace and cast into its first solid state, whether a semi-finished product such as a slab, billet or ingot, or a finished steel-mill product. Remelted scrap counts: the country where the scrap was remelted and recast is the country of melt and pour.

That definition reaches behind the customs origin of the goods. A coil rolled in one country from slab melted in another declares the melting country, not the rolling country. The declaration itself runs through TARIC document codes: C-codes C131 to C139 identify the supporting evidence, and Y-codes Y376 to Y387 identify the country of melt and pour. European Economic Area countries are exempt from the Steel Regulation's quotas and out-of-quota duty but remain subject to the traceability requirement.

One boundary matters for planning. The Steel Regulation treats melt-and-pour as a transparency and traceability requirement for now, not as the basis for allocating its tariff-rate quotas. From October 1, 2027 the Commission takes melt-and-pour data into account for the country distribution of quotas, and by June 30, 2028 it must assess whether melt-and-pour should become the full basis for quota allocation.

Which documents prove the country of melt and pour

The primary evidence is a Mill Test Certificate that states the country of melt and pour and the heat number; where the certificate lacks that information or cannot be produced, customs authorities may accept nine types of alternative documents. The alternatives can serve as a complement to the certificate or, during a transition period, as standalone evidence, provided they identify both the country and the heat number. The nine accepted alternatives are listed below.

• Invoices
• Delivery notes
• Quality certificates
• Purchase order and contract clauses
• Supplier declarations
• Production and cost accounting records
• Customs documents of the exporting country
• Commercial correspondence
• Production descriptions

The transition period runs from October 1, 2026 to September 30, 2027, during which alternative documents alone can carry the declaration. From October 1, 2027 the Mill Test Certificate becomes the mandatory base document, and the alternatives only supplement information the certificate is missing. Importers whose mills issue certificates without a melt-and-pour country line have twelve months to get the certificate format changed.

The triple compliance stack per steel shipment

A steel shipment entering the EU now answers to three regimes at once: CBAM prices its embedded emissions, the Steel Regulation controls its volume, and the melt-and-pour rules trace its metallurgical origin. The three are legally independent, a separation the Commission insists on and that Šefčovič restated when he ruled out any SME exemption from the Steel Regulation on September 1. The table below maps the stack.

The stack prices three different things. CBAM cost scales with carbon intensity, so the production route of the supplier matters. The 50 percent duty scales with timing, since it only hits imports after the relevant quota is exhausted. The melt-and-pour requirement carries no duty at all, but it gates entry: without the evidence, neither the quota nor the carbon math gets a chance to apply.

What happens when the proof is missing

Customs authorities reject an import declaration that is not supported by appropriate verifiable evidence of the country of melt and pour. Rejection is the hard stop, and it operates before any tariff question arises. Short of rejection, documentary checks on alternative evidence can delay access to the relevant tariff-rate quota, which has its own cost in a system where quotas for 30 product categories deplete on a first-come basis and out-of-quota entries pay 50 percent.

The exposure concentrates in supply chains with intermediate processing. An importer buying hot-dip galvanized coil from a service center that bought the substrate from a re-roller may hold a certificate from the last mill in the chain, not from the furnace that melted the steel. The heat number is the thread that connects the document to the melt, and it has to survive every step of the chain to the EU border.

What steel importers should do in October

Steel importers should close the evidence gap with suppliers now, while the alternative-document transition still provides slack. Four steps cover the near term:

1. Confirm which of your products fall under Annex I of Regulation (EU) 2026/1384, and separately which fall under CBAM Annex I. The CN code checker resolves the CBAM side.
2. Audit your Mill Test Certificates for the two required data points, country of melt and pour and heat number, and ask suppliers to amend their certificate format before the October 1, 2027 hard requirement.
3. Fold the request into your CBAM data collection. The supplier data request generator produces the emissions request; the melt-and-pour country line belongs in the same conversation, and the steel importer compliance guide covers the full CBAM obligation chain.
4. Update your Q4 cost model with the Q3 2026 certificate price of €82.32/tCO₂e, published October 5, which the price tracker carries alongside the earlier quarters.

Where the stack goes next

The stack grows before it shrinks. Parliament adopted its downstream mandate by 464 votes to 50 on September 15, which would extend CBAM to steel and aluminium downstream products from 2028 if the trilogue confirms it. On the Steel Regulation side, the melt-and-pour data that importers start filing this month feeds the Commission's quota-distribution review from October 2027. The evidence chain built now is not paperwork for its own sake: it is the dataset on which the next round of both regimes will be calibrated.