From 1 October 2026, companies importing steel products into the European Union will have to prove the origin of the steel imported into the EU and demonstrate the country in which the metal was melted and poured. Following this latest change, identifying the country from which the goods are shipped or where their last transformation took place will no longer be sufficient. Under the new system, importers must have information on the country of melt and pour and the heat number of the imported steel.
The main evidence will be the Mill Test Certificate or MTC, a certificate that links each product to its manufacturing process. These new obligations arise from Regulation (EU) 2026/1384, which establishes the new European framework for the steel market, and are further developed by Commission Implementing Regulation (EU) 2026/1963.
This article explains how to prove the origin of steel imported into the EU, what documentation importers must obtain and how companies can prepare for the requirements applying from 1 October 2026.
What changes does Commission Implementing Regulation (EU) 2026/1963 introduce?
Regulation (EU) 2026/1384 established the general obligation to declare and prove the country of the imported steel. Commission Implementing Regulation (EU) 2026/1963 now specifies which documents importers must provide, how customs authorities will check them and what happens when the evidence submitted is insufficient. The main changes are:
| Change | Practical consequence for the importer |
|---|---|
| The MTC becomes the main evidence | From 1 October 2026, importers must provide a Mill Test Certificate — referred to as a “mill certificate” in the English version of the Regulation — stating the country of melt and pour and the heat number of the steel. |
| Supporting documents are accepted | If an MTC exists but does not contain one of these details, it may be supplemented by invoices, delivery notes, quality certificates, executed contracts, long-term supplier declarations, production records, customs documents from the exporting country, commercial correspondence or production descriptions. |
| A transitional exception applies when no MTC is available | Between 1 October 2026 and 30 September 2027, these alternative documents may be accepted as evidence, provided that they establish both the country of melt and pour and the heat number. |
| Alternative documents will be checked | When supporting or standalone evidence is used, customs authorities must carry out documentary checks on the information and supporting documents submitted. Their acceptance is therefore not automatic. |
| The declaration will be made through TARIC | The country of melt and pour must be declared using the relevant TARIC document codes. The information must therefore be available before the customs declaration is lodged. |
| Lack of evidence may prevent the import | If the country of melt and pour is not declared or is not supported by appropriate and verifiable evidence, the customs authority must reject the import. |
| The rules will become stricter from October 2027 | From 1 October 2027, invoices and other alternative documents will no longer be able to replace the MTC on their own. They may only be used to supplement an incomplete mill certificate. |
This obligation forms part of a wider move towards customs controls based on data and cooperation between authorities, which is also reflected in the reform of the Union Customs Code. The main change is that the country of melt and pour becomes customs information that must be supported by documents. The Implementing Regulation does not establish a specific “fine” for the absence of an MTC, but it provides for the rejection of the import where no supported declaration is submitted. This may also lead to delays, storage costs and, depending on the circumstances, other forms of corporate liability for breaches of European Union rules.
What is the country of melt and pour of steel?
The country of melt and pour is the country in which crude steel or iron was produced in liquid form in a furnace and then poured into its first solid state. This concept also covers cases in which scrap metal is melted to produce new steel.
💡 For example, if steel was melted and poured in one country, subsequently rolled in another and exported to the European Union from a third country, the country of melt and pour will remain the first country. Rolling, cutting, coating or further processing does not change the place where the steel was produced in liquid form and poured.
Is this the same as traditional customs origin? This new obligation does not replace the general rules on the preferential or non-preferential origin of goods. It is an additional requirement. In the same commercial transaction, it will now be necessary to determine the customs origin of the product, the country from which the goods are exported, the country of melt and pour of the steel, the tariff classification and the applicable quota.
Which imports are covered by the new obligation?
The new obligation does not apply to all steel products. It only covers products listed in Annex I to Regulation (EU) 2026/1384. The first step is therefore to check the tariff code of the goods. If the code appears in the Annex, the importer must declare and prove the country in which the steel was melted and poured. Imports from the European Economic Area (EEA) must also comply with the obligation to provide information on the country. In addition to this specific obligation, companies must check the other customs and regulatory requirements for importing goods from outside the European Union, particularly when customs clearance takes place in Belgium.
The new regime opens annual tariff quotas with an aggregate volume of approximately 18.3 million tonnes. However, this volume is allocated by product category and country. When the applicable quota is exhausted, or when the import cannot benefit from it, a 50% ad valorem out-of-quota duty applies.
How can you determine whether your import is covered?
Before requesting new documents from the supplier, the following questions should be considered:
| Question | What must be checked |
|---|---|
| Is the product included in Annex I? | Check the Combined Nomenclature code and its correspondence with the categories in the Regulation. |
| Will the goods be imported from 1 October 2026? | The new obligation applies from that date. |
| Is an MTC available for the goods? | Check that the certificate relates to the product being imported. |
| Does the MTC state the country of melt and pour? | Stating the supplier’s country or the country of export is not sufficient. |
| Does it include the heat number? | The heat number must link the certificate to the goods. |
| Does the shipment include several heats? | Each consignment must be linked to its heat number, weight, country and MTC. |
How is the origin of the steel proved?
What is a Mill Test Certificate or MTC?
A Mill Test Certificate is a factory certificate issued by the steel plant that produced the steel. It usually contains information on the chemical composition, mechanical properties, technical standard, dimensions, manufacturing process and production batch. From 1 October 2026, the MTC must identify the country of melt and pour and the heat number of the imported steel. The MTC links the product to a specific heat. Until now, however, there has been no globally harmonised model and most certificates did not state the country.
💡 Example: if the MTC identifies heat number TR-45821, but the invoice or delivery note refers to batch TR-45128, the customs authority may consider that it has not been sufficiently demonstrated that the certificate relates to the imported steel.
The MTC will therefore become the main document used to verify the origin of steel imported into the EU and to connect each product with a specific heat.
What is a heat number?
The heat number is the identifier assigned to a quantity of steel produced during a melting operation. It serves as a reference for linking the finished product to the production batch, test results and information concerning the steel plant. The number must be linked to the imported goods and to the country declared as the place of melt and pour.
What documents may be used if the MTC is incomplete?
Where an MTC exists but does not state the country or heat number, customs authorities may consider supporting documents. Admissible documents include invoices and delivery notes, quality certificates, clauses in purchase orders or executed contracts, long-term supplier declarations, cost accounting and production documents, customs documents from the exporting country, commercial correspondence or descriptions of the production process. The customs authority may examine their connection with the imported consignment.
Transitional period until 30 September 2027
The European Commission has established a one-year adjustment period. Between 1 October 2026 and 30 September 2027, where an MTC cannot be provided, other documents may be accepted as evidence. This does not remove the obligation, and customs authorities must carry out documentary checks. Relying solely on invoices or other documents may therefore increase the risk of checks and delays in customs clearance.
💡 Recommendation: importers should not base their procedure on this exception. The use of alternative documents may lead to more extensive checks and delay customs clearance.
What changes on 1 October 2027?
From 1 October 2027, alternative documents will no longer be able to replace the Mill Test Certificate on their own. They may only be used to supplement an MTC that does not contain all the required information.
💡 In practice, companies that do not yet receive adequate factory certificates should use the transitional period to adapt their supply chain.
What should the importer prepare?
Compliance should not be limited to requesting an MTC from the supplier. The importer must check in advance that all the information can be linked to the products declared to customs.
1. Check the tariff classification of the product
First step is to determine the nomenclature code applicable to each product. The obligation to prove the country of melt and pour only applies to the categories listed in Annex I to Regulation (EU) 2026/1384. The following must also be checked:
- the relevant product category;
- the country of customs origin;
- the applicable tariff quota;
- the available balance under that quota;
- the possible application of the 50% out-of-quota duty;
- whether the goods may be covered by CBAM.
💡 Recommendation: any doubts concerning classification should be resolved before shipment.
2. Identify the steel plant and supply chain
The country of the seller, distributor or exporter does not necessarily correspond to the country of melt and pour. The importer must therefore know which steel plant produced the steel and who subsequently participated in its processing and sale. If the supplier is not the steel plant itself, it must obtain the information from manufacturers and intermediaries. Before confirming the order, the importer should ask the supplier to identify the steel plant, provide the address and country of the plant, state the country of melt and pour and the heat number or numbers, provide a preliminary copy or template of the MTC to be supplied and confirm that the certificate will correspond exactly to the goods shipped.
3. Require the MTC before shipment
The Mill Test Certificate must be available early enough to allow it to be checked. Importers should not wait until the goods arrive in the European Union, as any error may lead to checks, delays, storage costs or even rejection of the import. The importer must check that the MTC:
- identifies the manufacturer or steel plant;
- expressly states the country of melt and pour;
- contains the heat number;
- states the grade, technical standard, dimensions and composition;
- can be linked to the invoice, delivery note, packing list and transport documents;
- does not contain discrepancies in batch numbers, quantities or weights.
It must also be possible to demonstrate that the MTC relates to the steel covered by the customs declaration.
4. Prepare a breakdown where several heats are involved
A single invoice or shipment may contain steel from different heats, steel plants or countries. The importer should prepare a record identifying the following information for each consignment:
| Product or reference | Quantity or weight | Heat number | Country of melt and pour | Applicable MTC |
|---|---|---|---|---|
| Product A | — | — | — | — |
| Product B | — | — | — | — |
This correlation document must match the invoice, delivery note and transport documents. If the shipment contains products from different countries, the customs declaration must reflect that breakdown.
5. Is the MTC incomplete?
If the certificate does not state the country of melt and pour or the heat number, the importer must request a correction before shipment. Supporting documents containing this information may be provided, such as invoices, delivery notes, quality certificates, executed contracts, long-term supplier declarations, production records, customs documents from the exporting country or commercial correspondence. Between 1 October 2026 and 30 September 2027, these documents may be considered standalone evidence where an MTC cannot be provided. From 1 October 2027, they will no longer be able to replace the MTC. They may only be used to supplement an incomplete certificate.
💡 Recommendation: this transitional arrangement should be treated as an exceptional solution. From the outset, the company should establish a procedure based on receiving MTCs.
7. Review CBAM obligations
Where the product is also covered by the Carbon Border Adjustment Mechanism, the file must include the necessary information on the production installation and embedded emissions. The company must assess separately whether the product is subject to the obligation to prove the country of melt and pour, whether it falls within the scope of CBAM and whether the applicable annual threshold is exceeded — and therefore whether it is necessary to hold authorised CBAM declarant status.
8. Adapt contracts with suppliers
The documentary obligations must be expressly included in the contract, purchase order or general terms and conditions. Supplier should undertake to provide the MTC and the remaining documentation before shipment, guarantee the accuracy of the information and correct any discrepancy within a short period. The contract should also regulate the obligation to report any change of steel plant, production facility or heat, the provision of the information required for CBAM, the retention of supporting documents and liability. These obligations must be drafted precisely and adapted to the specific circumstances. For the main elements that should be addressed, see our guide on how to draft a business contract.
💡 These clauses do not replace the importer’s obligations towards the customs authority.
The MTC review should be integrated into the company’s general European regulatory compliance system, with defined internal responsibilities, checks and procedures.
Contractual clauses with suppliers
The importer depends largely on the information provided by its supplier. The new obligations concerning the origin of steel should therefore be expressly included in contracts, purchase orders and general terms and conditions. It is not sufficient to ask the supplier to state the origin of the goods. The contract must specify which documents must be provided, when they must be delivered and what happens if the information is incorrect or provided too late.
| Supplier obligation | What does this mean in practice? | Recommendation |
|---|---|---|
| Identify the country of melt and pour | The supplier must state where the steel was originally produced, not only the country from which it was exported. | Require this information for each consignment. |
| State the heat number | Each product must be linked to its heat number. | If a shipment includes several heats, request a breakdown by product, weight and quantity. |
| Provide the MTC | The supplier must provide the factory certificate relating to the goods. | Request it before shipment so that it can be checked in time. |
| Guarantee the accuracy of the information | The information in the MTC must match the invoice, delivery note and goods shipped. | Do not accept generic documents or documents that do not identify the goods. |
| Report any change | The supplier must report any change to the steel plant, material or intended batch. | Require prior approval before any substitution. |
| Retain supporting documents | The supplier must retain production records and the documents supporting the information provided. | Set a retention period and an obligation to cooperate during customs checks. |
| Accept responsibility for non-compliance | The consequences of providing false, incomplete or late information must be regulated. | Provide for reimbursement of costs attributable to the supplier. |
💡 Practical example: a shipment may include products from three different heats. In that case, providing a single MTC without further explanation will not be sufficient. The supplier must indicate which products correspond to each heat number, their weight or quantity, the country of melt and pour and the applicable certificate. This information must match the invoice, delivery note and transport documents.
💡 Recommendations for reducing risks: if the supplier is a distributor rather than the steel plant that manufactured the steel, it must undertake to obtain the information from operators further up the supply chain. The clause must also be adapted to the Incoterms, the point at which risk passes and the agreed rules on liability and limitation of damages. Its inclusion protects the importer in the contractual relationship, but does not replace the importer’s obligation to check the documents submitted to customs.
How does this obligation relate to CBAM?
The new rules on the country of melt and pour must be distinguished from the Carbon Border Adjustment Mechanism — CBAM —. Although both regimes may apply to the same steel import, they pursue different objectives. The system established by Regulations (EU) 2026/1384 and 2026/1963 aims to identify where the steel was originally melted and poured. CBAM, mainly governed by Regulation (EU) 2023/956, has a climate-related purpose.
Two different obligations
Compliance with the MTC requirements does not mean that an import complies with CBAM. Similarly, having the emissions data required under CBAM does not prove the country of melt and pour.
| Aspect | Country of melt and pour | CBAM |
|---|---|---|
| Purpose | Determine where the steel was originally produced in liquid form and where it was first poured. | Determine the embedded carbon emissions of the imported goods. |
| Main legislation | Regulations (EU) 2026/1384 and 2026/1963. | Regulation (EU) 2023/956, as amended by Regulation (EU) 2025/2083. |
| Application date | 1 October 2026. | Definitive regime from 1 January 2026. |
| Main document | Mill Test Certificate or mill certificate. | Information on emissions, the production installation and the calculation method and, where applicable, a verification report. |
| Essential information | Country of melt and pour and heat number. | Embedded emissions and any carbon price paid in the country of production. |
| Main consequence | The import may be rejected if the country is not declared using appropriate and verifiable evidence. | Authorisation, an emissions declaration and the purchase and surrender of CBAM certificates may be required, in addition to the consequences of non-compliance. |
The 50-tonne threshold does not remove the MTC obligation
Under the CBAM regime, importers or their customs representatives that exceed the single threshold of 50 tonnes of CBAM goods per calendar year must apply for authorised CBAM declarant status. This threshold applies only to CBAM. The Regulations on the country of melt and pour do not provide an equivalent exemption for small quantities. A company that does not exceed 50 tonnes and is outside certain CBAM obligations may therefore still have to declare and prove the country of melt and pour of its steel.
Imports from Norway and other EEA countries
Goods originating in Norway are excluded from CBAM. They are also exempt from the tariff quota system and the additional 50% duty established by Regulation (EU) 2026/1384. However, the obligation to declare and prove the country of melt and pour also applies to products imported from Norway. A transaction may therefore be excluded from CBAM but still require an MTC identifying the country of melt and pour and the heat number.
One document chain, but two legal checks
From an operational perspective, the company may request both the MTC and the information required for CBAM from the supplier. However, the checks must be carried out separately. For each product, it is necessary to determine whether the obligation to prove the country of melt and pour applies and whether the import is subject to CBAM.
💡 Practical example: a company imports 100 tonnes of steel into the European Union that falls within the scope of both Regulations. Even if the additional 50% customs duty does not apply, the company may still have to provide an MTC and comply with CBAM. The tariff quota, the origin of the steel and the cost of its emissions are separate and cumulative issues.
For this reason, contracts with suppliers should expressly require both the provision of an MTC and the information needed to calculate and verify CBAM emissions.
Common mistakes and how to avoid them
| Mistake | Possible consequence | Preventive measure |
|---|---|---|
| Declaring the supplier’s country | The declared country may not correspond to the place of melt and pour. | Request express confirmation from the producing steel plant. |
| Accepting an MTC without a heat number | The certificate cannot be linked to the goods. | Require a corrected certificate before shipment. |
| Failing to compare the MTC with the invoice | There may be discrepancies in the product, quantity or weight. | Carry out a combined documentary review. |
| Grouping several heats without a breakdown | The traceability of each consignment may be insufficient. | Prepare a record by heat, product and weight. |
| Relying only on a commercial declaration | The authority may request additional evidence. | Retain production, quality, transport and export records. |
| Receiving documents after shipment | Corrections may arrive too late. | Set a contractual deadline for providing the documents. |
| Failing to include the obligation in the contract | The importer may have difficulty recovering costs from the supplier. | Include a specific clause on documentation and liability. |
Where the documents do not properly support the import, the goods may be blocked during customs clearance. Our guide on goods detained by customs explains the main reasons for detention and the possible courses of action.
Practical examples concerning the origin of imported steel EU
The following examples are fictional and are provided for explanatory purposes only. They show how the new obligations may apply to different commercial transactions.
Steel melted in India, rolled in Turkey and exported to Belgium
A Belgian company purchases steel coils from a distributor established in Turkey. The invoice and transport documents are issued by the Turkish company, but the steel was initially melted and poured in India. It was then sent to Turkey for rolling and exported from there to Belgium. In this transaction, Turkey is the country of export and subsequent processing. However, India is the country of melt and pour. The importer must have an MTC identifying the Indian steel plant and the relevant heat number. It would not be sufficient to declare Turkey merely because the invoice and shipment originate there.
💡 Recommendation: where the supplier is not the steel plant that manufactured the steel, it should be required to obtain the original MTC and the documents needed to reconstruct the supply chain.
Importing steel from Norway
A Spanish company purchases steel products from a manufacturer established in Norway and imports them into the European Union after 1 October 2026. As the goods come from a country in the European Economic Area, the transaction is not subject to the quota mechanism or the additional duty established under the new regime. However, the importer must still declare and prove the country of melt and pour. If the steel was melted and poured in Norway, the MTC must state this. If it was originally manufactured in another country and only processed in Norway, the country where the melting and pouring took place must be declared.
💡 Recommendation: imports from the European Economic Area should not be assumed to be entirely excluded from the new documentary obligations.
The supplier does not have a complete MTC during the transitional period
In February 2027, a French company imports steel sheets from South Korea. The supplier has a quality certificate, but the MTC does not expressly state the country of melt and pour. To complete the information, the supplier provides a signed declaration, production records, the invoice, the delivery note and export documents. All these documents identify the production plant, the country of melt and pour and the heat number. As the import takes place during the transitional period, these documents may be considered by the customs authority. Their acceptance should not, however, be regarded as automatic: customs may check their authenticity, consistency and connection with the imported goods.
💡 Recommendation: although alternative documents may be accepted during the transitional period, the company should request a complete MTC as soon as possible. From 1 October 2027, these documents may only be used to supplement the certificate.
A single shipment contains steel from several heats
A Dutch company imports 500 tonnes of steel under a single invoice. However, the goods come from three different heats: two were produced in China and one in Vietnam. The supplier provides three MTCs, but the invoice does not indicate which part of the shipment relates to each certificate. There is also no breakdown of the weights linked to each heat number. In these circumstances, the documentation may be insufficient even if all three certificates are authentic. The customs authority must be able to link each product or part of the goods to its heat number, country of melt and pour and MTC.
The MTC does not match the invoice
An Italian company imports steel profiles from Egypt. The supplier provides an MTC stating heat number EG-24781. However, the commercial invoice identifies the batch as EG-24718, and the stated weight does not match the delivery note. Although this may be a simple error, the documents do not make it possible to verify with certainty that the MTC relates to the origin of imported steel in the EU. The importer should ask the supplier to correct the information before shipment and before the customs declaration is lodged. If the discrepancy is detected during a check, customs may request additional evidence and delay clearance while verifying the origin of the product.
💡 Practical recommendation: before each shipment, the MTC should be compared with the invoice, delivery note, packing list and transport documents. At a minimum, the product description, quantity, weight, heat number and country of melt and pour must match. The contract should also require the supplier to correct any documentary error promptly and bear the costs attributable to it.
Do you import steel into the European Union? Prepare before 1 October 2026
The new European regime makes steel traceability a condition for market access. From October 2026, companies will need to know not only who sells them the product or where it is exported from, but also where the steel was produced and which heat it belongs to. The transitional period offers some flexibility, but it should not delay compliance. Importers that establish a system based on MTCs and contracts adapted to the new requirements will reduce the risk of checks, delays and unexpected costs.
At Arthur & Marin, we provide specialist customs law advice to importers, manufacturers and distributors on how to prove the origin of steel imported into the EU. We determine whether products are covered, review MTCs and supporting documents and assist with inspections, detentions and other customs issues. We also advise on international contracts, supplier relationships and the allocation of responsibilities in International trade. Where a transaction is simultaneously subject to different European rules — such as the steel regime and CBAM — our European Union law and Regulatory law team can review the applicable obligations together.
Contact us at info@arthurmarin.com or on +32 465 345 345 to request a review of your import procedure and receive a proposal adapted to your company.
Frequently asked questions about the origin of steel imported into the EU
When does the new obligation apply?
From 1 October 2026. From that date, importers must declare and prove the country of melt and pour of the steel products covered by the Regulation.
Is an MTC always required from October 2026?
The MTC is the main evidence. During the transitional period ending on 30 September 2027, alternative documents may be accepted as standalone evidence where no MTC is available, provided that they establish the country of melt and pour and the heat number.
How can importers prove the origin of steel imported into the EU?
Importers must generally provide a Mill Test Certificate identifying the country of melt and pour and the relevant heat number. During the transitional period, other documents may be accepted or used to complete an incomplete MTC, subject to verification by the customs authorities.
Can an invoice replace the MTC?
Until 30 September 2027, an invoice or other admissible document may be considered standalone evidence if it contains sufficient and verifiable information on both points. From 1 October 2027, it may only be used to supplement the MTC.
Is the country of export the country of melt and pour?
Not necessarily. Steel may be melted in one country, processed in another and exported from a third. The place where it was originally produced in liquid form and poured into its first solid state must be identified.
What happens if a shipment includes several heats?
Each part of the goods must be linked to its heat number, country of melt and pour and supporting documents. A general reference that does not distinguish between the different consignments may be insufficient.
Who bears the risk towards customs?
Although the supplier must provide the information, the importer must ensure that the customs declaration is properly supported. The contract may allocate costs and responsibilities between the parties, but it does not remove the operator’s obligations towards the customs authority.
