EU Steel Regulation: “Melt and pour” evidence from 1 October

On 31 August 2026, the European Commission adopted an implementing act on evidence for the country where steel was melted and poured. It applies from 1 October 2026. For China importers, heat traceability is moving from a technical detail to a purchasing document.

The critical declaration

The importer must declare and support the melt-and-pour country. A commercial invoice saying “China” describes origin, not necessarily where the steel was made.

Link MTC to the heat

Request the Mill Test Certificate, heat, coil or batch number and its allocation to the ordered quantity. Check that the number appears on the packing list and goods.

Plan quota and surcharge scenarios

The measure uses an EU-wide quota and a charge above quota. Model missing evidence, delay and additional duty in the landed-cost file.

Practical checklist

1. Identify steel SKUs and codes that may require the evidence.
2. Add the melt-and-pour field and document list to purchase orders and the supplier portal.
3. Before container release, reconcile MTC, heat number and quantity against the packing list.
4. Agree an escalation path with broker and supplier for missing or inconsistent evidence.

<!-- Longform expansion: research review 2026-09 -->

Decision frame for your import

The implementing act announced on 31 August 2026 applies from 1 October 2026. For covered steel goods, importers must declare the country of melt and pour. A factory name or “Made in China” is not enough. A mill test certificate (MTC) with country and heat number is the core evidence; complementary documents have a transitional role until 1 October 2027.

Data and document pack per item

For each coil, batch or semi-finished input, collect customs code, plant, melt-and-pour country, heat number, MTC, invoice, packing list and transport reference. If the MTC is unavailable, record invoices, delivery notes, quality certificates, purchasing or production records and supplier correspondence used as interim evidence. From October 2027 such records can supplement, not replace, the MTC.

• Trace the heat number from MTC to coil or bundle label.
• Reconcile MTC, invoice, packing list and customs line for quantity and grade.
• Do not infer melt country from seller country.
• Model quota status and any 50% duty in the import calculation.

A verification workflow from supplier to import

1. Before ordering, establish whether the item is covered.
2. Put MTC fields and a sample into the purchase order.
3. Before shipment, compare heat number, country and quantity with physical marks.
4. If MTC is missing, collect interim documents and record the transition deadline.
5. After 1 October 2027, release only complete MTC chains.

A worked decision example

A Chinese trader offers steel strip rolled in China but melted from another origin. The invoice says only China. The importer requests the MTC and heat number, links them to the coil label and delivery note, and declares the actual melt-and-pour country. Quota and duty review can then use traceable evidence.

Common failure modes and countermeasures

• Confusing seller country with melt country — require process evidence.
• Accepting an MTC without a heat number — create physical traceability.
• Using interim papers as a permanent MTC substitute — monitor 1 October 2027.
• Checking quota and duty only on arrival — model before ordering.

Message to send to the Chinese supplier

Put the document duty directly into the order:

For each batch, please provide an MTC with melt-and-pour country, grade, quantity and heat number. Please mark the heat number on the coil/bundle and use it on packing list and invoice. Please notify us before shipment of any different melting route or plant.

Release criteria for the file

A release is defensible only when four questions can be answered from the same record: What exactly was checked? Which SKU, batch, route or period does the statement cover? Which primary source or supplier document supports it? Who assessed the deviation and when is it reviewed again? Put those answers in the inspection report instead of marking a line only “passed”. Link the file to the order, sample and receipt. If evidence is missing, give the line an “open” status with an owner and due date. This keeps later corrections traceable and lets procurement distinguish evidence from assumptions.

Follow-up and recheck

Approval is not the end of the check. Set a trigger for the next review: a new batch, material or process change, an authority notice, a price or lead-time deviation, or the scheduled review date. A short monthly reconciliation of orders, supplier data and received goods catches drift earlier than an annual catch-up. When a deviation appears, hold the affected batch, obtain a written supplier response and reopen approval only after a documented corrective record.

<!-- Release template: research review 2026-09 -->

Internal release template

A check mark saying “reviewed” is not enough for this topic. In one short line, state that trace the heat number from MTC to coil or bundle label.. Add the exact scope (SKU, batch, plant, shipment or period), the primary source and document version. The second line records the open assumption or deviation, its owner and due date. The third line records the release decision and which shipment or version remains on hold. Another colleague should be able to reproduce the decision without searching an entire email thread.

Conclusion

Looking for the heat number at customs is too late. The chain must start at the mill and end at the specific import line.

Frequently asked questions

Is a Chinese certificate of origin enough?

Not necessarily. The new evidence concerns the melt-and-pour country; check the documents required for your goods.

When does an MTC become the primary evidence?

The Commission notice names 1 October 2027 for MTC as primary evidence. Request it already for the 1 October 2026 start.

Is a certificate of origin enough for melt and pour?

Not automatically. The Commission measure concerns the country of melt and pour; the MTC is the central evidence.

What if the MTC is temporarily unavailable?

Until 1 October 2027 certain complementary or alternative records may be relevant. Record the gap and plan the full MTC chain.

Sources

• Europäische Kommission: Melt-and-Pour-Nachweis