Melt and pour: new steel customs field from 1 October

From 1 October 2026, an importer of steel products covered by the EU Steel Regulation must declare the country of melt and pour. This is the country in which the steel was melted and poured. The importer must also be able to support that declaration with evidence.

This is not a CBAM rule. We cover it because it reaches the same desk, asks for the same document and applies first.

What was adopted

The Commission adopted an implementing act on 31 August 2026. The act sets the type of evidence that importers must provide to prove the country of melt and pour. Member States backed it unanimously on 19 August.

The act responds to a requirement that the Steel Regulation already contains. The Steel Regulation entered into force on 1 July 2026.

Why the rule exists

Melt and pour is the enforcement tool of the Steel Regulation, not a standalone idea. The Regulation sets free-of-duty quotas of 18.3 million tonnes. Imports above the quota pay a 50% duty. The quotas and the duty apply to all origins except EEA countries.

A 50% duty gives importers a strong incentive to name a false country of origin for their steel. The melt-and-pour declaration is how customs tests that origin.

The evidence importers must hold

The primary document is the Mill Test Certificate (MTC). It must show two items: the country of melt and pour and the heat number. The heat number ties a certificate to a specific batch of steel, not to a supplier's general practice.

Sometimes the MTC is missing, or it shows only one of the two items. In that case, customs authorities may accept other documents. The implementing act lists them:

• invoices and delivery notes;
• quality certificates;
• clauses in implemented purchase orders or contracts;
• long-term supplier declarations;
• cost accounting and production documents;
• customs documents from the exporting country;
• commercial correspondence;
• production descriptions.

Each document must itself state the country of melt and pour and the heat number.

The change after one year

From 1 October 2027, those documents will be accepted only as complementary to the Mill Test Certificate, not as standalone evidence.

This gives importers a one-year window. During that year, a well-documented commercial file can stand in for a proper MTC. After that year, the window closes.

Why a CBAM site covers a trade measure

Both rules ask the same supplier the same kind of question, eighteen months apart. The answer comes from the same place.

Melt and pour asks where this steel was actually made. CBAM asks what emissions are embedded in it. Neither question can be answered from the commercial name on an invoice.

Both are answered from production records at a named installation, tied to an identifiable batch. The Mill Test Certificate and its heat number connect the two answers.

What it means for importers

An importer who spends the year collecting invoices and correspondence, and does not fix the certificate, has solved the wrong problem. That importer then meets the one-year change with no time left.

There is one piece of good news. An importer who gets melt and pour right in October 2026 will have built most of the supplier relationship that CBAM's actual-emissions route needs later. That relationship has a named installation and a batch-level identifier. It also has a supplier used to being asked for production evidence rather than assurances.

An importer who only gets through on commercial correspondence builds nothing reusable and meets the same problem twice.

What to do

• Establish whether your goods are in scope. The Steel Regulation covers specific products, and this obligation follows that scope, not a general idea of "steel". Check the CN codes on your declarations against the Regulation. Do not judge by the product's name.
• Pull one MTC from each supplier and look for two fields: the country of melt and pour, and the heat number. Check that these two fields are on it, not only that a certificate exists. The check takes ten minutes and shows whether you have a problem. Most importers have never had a reason to look.
• Where a field is missing, ask the mill now. A mill can reissue a certificate with the country and heat number on it. A mill cannot reissue a certificate for a consignment that is already at the border.
• Treat the 2027 date as the real deadline. Standalone alternative evidence is a transitional accommodation, not a permanent route. If your answer to melt and pour is "we have good paperwork", you have twelve months to convert that paperwork into certificates.
• Read the implementing act itself where a classification or evidence question is decisive for a consignment. We have summarised the evidence list and have not reproduced its operative wording.

Stuck on this in your own import data? Write to us and we will look at it with you.

This article explains a trade measure, not a CBAM obligation, and nothing here changes a CBAM declaration. It is not legal, tax or customs advice.