On August 31, 2026, the European Commission adopted an implementing act fixing the evidence importers must file to prove the country of "melt and pour" of steel products entering the EU under the Steel Regulation. The act, backed unanimously by Member States on August 19, applies from October 1, 2026, converting a traceability principle into a customs-filed documentation obligation with a hard deadline.
The implementing act (OJ L 2026, 1963) executes the EU Steel Regulation (Regulation (EU) 2026/1384), which entered into force on July 1, 2026. From October 1, every importer of steel subject to the Regulation must declare on the customs declaration the country in which the steel was melted and poured, and back that declaration with the evidence the act now specifies.
What evidence must importers file from October 1, 2026?
The primary document is a Mill Test Certificate that records both the country of melt and pour and the heat number of the imported steel. Where the certificate omits either field, or where no certificate can be produced at all, customs authorities may accept complementary or standalone evidence, provided it still carries the melt-and-pour country and the heat number: invoices, delivery notes, quality certificates and clauses in implemented purchase orders or contracts, long-term declarations from suppliers, cost accounting and production documents, customs documents from the exporting country, commercial correspondence, or production descriptions.
The two-tier design follows feedback from nearly 170 stakeholders in a targeted consultation that ran from June 2 to July 4, 2026. The Commission drew the fallback list from documents importers already exchange in day-to-day transactions, to avoid layering a new documentation burden while still securing reliable traceability for customs.
| Document | From October 1, 2026 | From October 1, 2027 |
|---|---|---|
| Mill Test Certificate (melt-and-pour country + heat number) | Primary evidence | Primary evidence, still required |
| Invoices, delivery notes, quality certificates, long-term supplier declarations, cost and production documents, exporting-country customs documents, commercial correspondence, production descriptions | Complementary to the Mill Test Certificate, or standalone | Complementary only, no longer standalone |
Which importers and steel products fall under the rule?
The obligation attaches to all steel products covered by the Steel Regulation, regardless of origin, with one carve-out: EEA countries remain subject to the melt-and-pour traceability requirements but sit outside the quota and duty mechanism. The Regulation sets free-of-duty quotas at 18.3 million tonnes, with a 50% duty levied on imports above those quotas, and traceability is the enforcement lever that lets authorities verify where steel was actually melted and poured.
For compliance teams, the practical trigger is the customs declaration filed for each consignment of in-scope steel. The melt-and-pour country must be stated there, and the supporting evidence must be obtainable from the supply chain, which places the documentary burden on the importer and its non-EU suppliers rather than on EU authorities.
What tightens on October 1, 2027?
From October 1, 2027, the fallback documents listed above will be accepted only as complementary to a Mill Test Certificate, not as standalone proof. Importers that today rely on invoices or delivery notes in lieu of a certificate will need a Mill Test Certificate carrying the melt-and-pour country and the heat number for every consignment. Contracts with non-EU mills should be amended now to guarantee the certificate is issued in the required form, because the one-year window is the period the Commission has given industry to migrate onto the primary document.
Obsidian's continuous, per-jurisdiction monitoring surfaces this kind of change the moment it publishes in the Official Journal.
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Before October 1, 2026, compliance teams should:
- Confirm whether imported steel products fall under the Steel Regulation's product scope, and map each customs declaration to the new melt-and-pour country field.
- Verify with non-EU suppliers that Mill Test Certificates already carry the melt-and-pour country and the heat number; re-specify the certificate where they do not.
- Where only fallback documents exist today, plan the migration to a compliant Mill Test Certificate before the October 1, 2027 standalone cutoff.
- Brief customs brokers and trade-operations staff on the new declaration field and the two evidence tiers.
The October 1, 2026 deadline leaves roughly 30 days to align certificates, contracts, and customs declarations. Importers that start the supplier conversation now avoid the scramble the 2027 tightening would otherwise force.
