Steel and traceability

Steel imports: proof of the ‘melt and pour’ country is now required

Since 1 October 2026, imports covered by the Steel Regulation must identify where the material was melted and poured. The key document links the country to the heat number.

EC HolaHome team · Published: · Sources checked:

Since 1 October 2026, the ‘melt and pour’ traceability requirement has applied to products covered by the new EU Steel Regulation. For companies buying in China, the check needs to start before the order is confirmed: knowing who sells the goods or which port they leave from does not show where the steel was made.

Sources: European Commission: type of evidence for the ‘melt and pour’ country (31 August 2026)

What ‘melt and pour’ means

It identifies the country where the steel or iron was first produced in a liquid state and then cast into its first solid form. That may differ from the country where the product was later rolled, cut, processed or sold. It is not automatically the same as the non-preferential origin declared to customs or the country of dispatch.

If a Chinese company buys steel from elsewhere and processes it, it is advisable to trace the chain back to the steel mill rather than rely only on a statement from the intermediary.

Sources: European Commission: type of evidence for the ‘melt and pour’ country (31 August 2026)

Which operations are affected

You need to check whether the product and its code fall within the scope of Regulation (EU) 2026/1384. Not every article that contains steel is covered for that reason alone.

The documentary requirement is a traceability obligation within this framework. It does not replace checks on the applicable quota or duty, origin, trade measures or CBAM requirements where relevant. Meeting the ‘melt and pour’ requirement does not by itself show that an operation is exempt from other controls.

Sources: Regulation (EU) 2026/1384 (steel) · European Commission: type of evidence for the ‘melt and pour’ country (31 August 2026)

Which documents need to be prepared

The main reference is the Mill Test Certificate issued by the steel mill. It must make it possible to identify the ‘melt and pour’ country and the heat number of the imported steel.

Until 30 September 2027, if the certificate is missing or does not contain all of that information, customs authorities may consider other documents as independent or supporting evidence. The Commission mentions, among others, invoices, delivery notes, quality certificates, production documents, supplier declarations and clauses in executed orders or contracts. It is not enough for a document to exist: it must provide the required data and be linked to the goods.

From 1 October 2027, those alternative documents may only supplement the Mill Test Certificate, not replace it. Their acceptance and sufficiency are assessed at clearance; neither the supplier nor a buying agent can guarantee them.

Sources: European Commission: type of evidence for the ‘melt and pour’ country (31 August 2026) · Commission Implementing Regulation (EU) 2026/1963

What to request from the factory before shipment

  • Identification of the steel producer and of the factory that processes or supplies the product.
  • The ‘melt and pour’ country and a certificate showing the heat number.
  • A verifiable link between heats, references, quantities and order batches.
  • Consistency between the certificate, invoice, packing list and markings on the goods.
  • Confirmation with the customs representative of the applicable scope and supporting documents.

If goods from several factories are consolidated, keep the documentary link for each batch: putting packages in the same shipment does not merge their origin or heats.

How it fits with CBAM

‘Melt and pour’ and CBAM answer different questions. The first identifies where the steel was obtained; CBAM requires an analysis of code, origin, mass and emissions, among other data, as explained in our CBAM imports guide. A Mill Test Certificate does not replace emissions data or accredited verification.

At EC HolaHome we can coordinate with suppliers to request and organise documents and to communicate with the professionals involved in the operation, as part of our import management. If you buy sections, reinforcement or other metal products for construction, see also the building materials guide.

Frequently asked questions

Is the invoice country or port of loading enough?
No. The ‘melt and pour’ country is where the steel was first melted and cast. It may not match the seller’s country, the port of departure or the declared non-preferential origin.
Does the Mill Test Certificate serve as a CBAM document?
No. It shows mill and heat data, but it does not replace emissions data or their verification where CBAM applies.

Guidance for businesses. Confirm the scope and documents for each operation with your customs representative.

Official sources

Sources checked: · Last updated:

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Tell us which steel product you buy, from which factories and how batches are grouped. We can coordinate with suppliers on the documents worth gathering.

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