New EU steel documentation requirements apply from 1 October

1 October 2026

 

UK businesses exporting certain steel products to the EU need to be aware of new documentation requirements that apply from 1 October 2026.

Under the EU Steel Regulation, importers of steel products covered by the measures must now declare the country in which the steel was originally “melted and poured” when the goods are imported into the EU.

The new requirement is intended to improve the transparency and traceability of steel entering the EU and applies to steel product categories covered by the Regulation.

What does “melt and pour” mean?

The country of “melt and pour” is the original location where raw steel or iron is initially produced in liquid form within a steel or iron-making furnace and subsequently cast into its first solid state following melting, including the remelting of scrap.

Importantly, this is not necessarily the same as the country where the finished steel product was subsequently manufactured, processed or exported from.

For example, steel could be melted and poured in one country before being processed or manufactured into a subsequent steel product in another.

For UK exporters, this distinction means that knowing the country of manufacture or export may no longer be sufficient. Businesses may need to look further back through their supply chain to establish where the steel was originally melted and poured and obtain evidence to support that information.

What evidence is required?

Under the new EU evidence requirements, at the point of import into the EU, the importer must provide a Mill Test Certificate (MTC) that includes:

  • the country of melt and pour
  • the heat number of the imported steel

If the MTC does not contain either of these pieces of information, EU customs authorities may consider other documents as complementary evidence, provided they contain the missing information.

These can include:

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

Until 30 September 2027, these alternative documents may also be considered as standalone evidence where an MTC cannot be provided, provided they contain both the country of melt and pour and the heat number.

Where the country of melt and pour is evidenced using these alternative or complementary documents, EU customs authorities are required to carry out documentary checks on the information and supporting evidence submitted. This additional verification may delay access to the relevant tariff-rate quota while the checks are completed.

From 1 October 2027, the listed alternative documents will only be accepted as complementary evidence alongside the Mill Test Certificate and will no longer be accepted as standalone evidence.

What does this mean for UK exporters?

Although the legal obligation at the EU border falls on the importer, UK businesses supplying affected steel products may need to provide their EU customers with the information and documentation required to complete the import process.

The country of melt and pour must also be declared to EU customs using TARIC document codes.

Businesses exporting covered steel products should:

  • confirm whether their products fall within the scope of the EU Steel Regulation
  • establish where the steel used in their products was originally melted and poured
  • avoid assuming that the country of manufacture is also the country of melt and pour
  • check that Mill Test Certificates contain the required information
  • ensure the relevant heat number can be identified
  • work with manufacturers, stockholders and suppliers to obtain supporting evidence where necessary
  • make the required information available to their EU customer or importer before the goods reach the border

This may be particularly important for businesses purchasing steel through manufacturers, stockholders or distributors. The information needed to establish the original country of melt and pour may sit further back in the supply chain and may not previously have formed part of the documentation routinely obtained by the exporter.

Failure to declare the country of melt and pour with appropriate, verifiable evidence can result in EU customs rejecting the import. Businesses exporting affected products should therefore establish whether the requirements apply to their goods and ensure the necessary information can be provided before shipping.

 

By Carla Assunção, Chamber International

 

If you are unsure how the new requirements affect your exports, we can help you understand your customs and documentation requirements and prepare your goods for export to the EU. Speak to our team.

 

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