EU
European Union · Trade defence measure · Steel sector
Regulation COM(2025) 726 · applicable from 1 July 2026

Steel and customs The new EU safeguard mechanism and the "melted and poured" rule: how to prove the real origin of imported steel

Instrument
EU regulation on steel safeguards
COM(2025) 726, replaces Reg. (EU) 2019/159
Entry into force
1 July 2026
upon expiry of the current measure (30 June 2026)
The practical question
If tomorrow customs asked for proof of the country of melting and pouring, could your suppliers provide it?
For many, not yet.
The essence of the change

It is no longer enough to know from whom you buy. You will have to prove where the steel was actually melted and poured. Commercial origin (invoice, certificate of origin) and the real origin of the metal may diverge, and the burden of proof shifts to the importer.

01

What changes from 1 July 2026

Four changes. The first hits costs; the fourth (the truly difficult one) hits the evidence.

01 · Volume

The duty-free quota shrinks

The volume of steel that can enter the EU without additional duties is capped at around 18.3 million tonnes per year, managed quarterly, by product categories.

~33 mil. tbecomes18.3 mil. t
02 · Duty

The out-of-quota duty doubles

For quantities that exceed the available quota, the safeguard duty increases from 25% to 50% ad valorem.

25%becomes50%
03 · Origin
key

The melted-and-poured rule

The relevant origin of the steel is determined by reference to the country where it was first "melted and poured", not by the last processing or the country of shipment.

04 · Evidence
the hardest

The burden of proof shifts to the importer

Importers will need to evidence in documents where the steel was actually produced. The mill certificate and the traceability of the chain become essential.

2019, June 2026

The current safeguard measure, set up by Reg. (EU) 2019/159: tariff-rate quotas with a 25% duty out of quota. Expires on 30 June 2026.

7 October 2025

The European Commission presents proposal COM(2025) 726, based on the Steel and Metals Action Plan.

13 April 2026

Political agreement between Parliament and Council and favourable vote in Parliament. The text is to undergo formal adoption and publication in the Official Journal.

1 July 2026

The new mechanism enters into force and replaces the current measure.

by 31 August 2026

The Commission is to adopt the implementing act specifying exactly what evidence importers must present for the "melted and poured" rule.

02

The concrete scenario

You import a steel product. What you check today and what you may be asked tomorrow.

Today, what you checkcurrent practice
  • Commercial invoice
  • Certificate of origin
  • Transport documents
Origin: the country you buy from (North Macedonia)
Where the trap appears
The imported product
Made in North Macedonia
but
The steel
Comes from Turkey
and
Melting and pouring
Took place in another third country

The product is Macedonian, but the steel is not. In this case, the relevant origin under the new rules is no longer North Macedonia, but the country of melting and pouring, and if you cannot prove it with documents, you face the worst treatment.

03

The logic: can you prove the origin?

Four questions in a chain, from "does it fall within the scope of the measure" to "with or without the 50% duty". Click any test for the argument.

No additional duty
Risk: 50% or customs block
Final favourable outcome
Starting pointImport of a steel product, after 1 July 2026
Test 1: Scope why it matters
Does the product fall within the listed categories (CN code in Annex I to the regulation)?
Argument
The measure covers around 30 categories of steel products, identified by CN codes (rolled sheets, heavy plates, galvanised products, bars, wire, tubes, etc.). If the product is not on the list, the measure does not apply, but note: the regulation provides for reviews at 6 and 12 months that may extend the scope (tubes, certain wires, forged bars, products with significant steel content).
Test 2: Country of melting and pouring why it matters
Do you know the country in which the steel was actually melted and poured (not just the country of purchase or shipment)?
Argument
The "melted & poured" rule shifts the relevant origin to the first metallurgical step. A product made in North Macedonia from steel melted elsewhere has, for this measure, its origin in the country of melting. If you do not know that country, you cannot establish either the applicable quota or whether the product comes from a source targeted by anti-circumvention.
If NO

Origin undetermined. You face the worst treatment and customs delays.

Test 3: Documentary evidence why it matters
Do you have the documents that evidence that country (mill certificate, traceability documents, supplier's declaration)?
Argument (the decisive point)
Knowing is not the same as proving. The burden of proof rests with the importer, and customs may request the documentation at any time. The exact list of accepted evidence will be set by an implementing act (expected by 31 August 2026). Without evidence, the declaration of origin does not stand up.
If NO

You cannot demonstrate compliance. Risk of a 50% duty, reclassification or refusal at import.

● This is where the imported-product scenario falls
Test 4: Available quota why it matters
Is there still free quota for that category (and, where applicable, for the real country of origin) in the relevant quarter?
Argument
Even with origin proven, duty-free access depends on the remaining quota. Quotas are managed quarterly, without carry-over between periods. Once the quota is exhausted, the 50% out-of-quota duty applies. Quarterly planning and dual cost modelling (in-quota vs. out-of-quota) become essential.
If NO

Quota exhausted. Import is possible, but with a 50% ad valorem duty.

Where the chain breaks for most importers

Not at Test 1 (the CN code) nor at Test 4 (the quota). The critical point is Test 3: many know the country of melting, but cannot yet prove it. That is why the question "could your suppliers, tomorrow, provide the mill certificate and the traceability?" is the real readiness test for 1 July 2026.

04

Why the melting and pouring rule

The logic of the measure, step by step, from the underlying problem to the burden of proof.

The underlying problem: overcapacity

Global steel overcapacity is estimated to reach around 721 million tonnes by 2027, more than five times the EU's annual consumption. Restrictions in other markets (e.g. US tariffs) redirect these volumes towards the EU.

The instrument: a smaller quota and a higher duty

Reducing the duty-free quota (to 18.3 million tonnes) and doubling the out-of-quota duty (to 50%) discourages excessive imports while preserving controlled access for traditional flows.

The risk: circumvention through re-shipment

A higher duty creates an incentive to "launder" the origin, that is, to finalise a product in a country with a favourable quota although the base steel comes from a targeted source. Commercial origin would become a smokescreen.

The solution: anchoring origin in metallurgy

The "melted and poured" rule fixes origin at the first real step of steel production. In this way, the last processing or the country of shipment can no longer mask the metal's provenance.

The consequence: burden of proof on the importer

For the rule to apply, someone has to demonstrate it, and that someone is the importer. Hence the central role of the mill certificate and traceability, with the precise evidence to be set by the implementing act.

05

The key message

For many companies, the challenge will not be the duty, it will be the evidence.

Practical conclusion

The real challenge of the new mechanism is not the application of the 50% duty, it is demonstrating compliance. It is no longer enough to know the country you buy from; you will have to know, and be able to prove, the country where the steel was actually melted and poured. The mill certificate, the traceability documents and the verification of the supply chain become essential elements of the import process.

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06

Glossary

Click a term for its definition and its relevance to this measure.

07

Practical effects

What the measure means for importers and for the supply chain.

Dual cost, quarterly planning

With the reduced quota and the duty at 50%, more shipments will fall outside the quota. Build dual cost models (in-quota vs. out-of-quota) and plan by quarter, without relying on carry-over.

Real origin, not commercial origin

The invoice and the certificate of origin may no longer be enough. The decisive factor is the place of melting and pouring, which may differ from the country of the supplier.

Contractual traceability

Include in contracts the obligation of suppliers to deliver the mill certificate and the melting-and-pouring evidence. Test now whether they can, not on 1 July.

Watch out for circumvention

Structures of the type "made in country X from steel melted in country Y" will be exactly the target of the rule. Mapping the real source of the metal becomes mandatory.

EEA: exempt from quota, not from proof

Imports from EEA states (Norway, Iceland, Liechtenstein) remain outside the quotas, but are still subject to the melting-and-pouring requirement.

Watch out for scope expansion

The 6 and 12-month reviews may bring tubes, certain wires, forged bars and products with significant steel content within scope. Monitor the CN codes.

Readiness checklist for 1 July 2026
  • Do my products fall within scope? Check the CN codes against Annex I and follow the reviews.
  • Do I know the country of melting and pouring for each supplier and product?
  • Can I immediately obtain the mill certificate and the traceability documents from suppliers?
  • Do I have contractual clauses that bind the supplier to provide this evidence?
  • Have I modelled the cost in-quota vs. out-of-quota, by quarter, for each product line?
  • Am I tracking the implementing act (by 31 August 2026) that sets the accepted evidence?
Sources: Proposal for a Regulation COM(2025) 726 (European Commission, 7 Oct. 2025); Implementing Regulation (EU) 2019/159 and subsequent amendments; communications of the European Commission, the Council of the EU and the European Parliament (13 Apr. 2026); EU rules on the origin of goods applicable to steel products.

An educational document, a simplified logical scheme of the new mechanism. At the time of writing, the text was undergoing formal adoption and publication in the Official Journal; figures and deadlines may be adjusted. It does not constitute legal, tax or customs advice. For application to a specific case, please contact us.

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