COM(2025) 726, replaces Reg. (EU) 2019/159
Steel and customs The new EU safeguard mechanism and the "melted and poured" rule: how to prove the real origin of imported steel
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.
What changes from 1 July 2026
Four changes. The first hits costs; the fourth (the truly difficult one) hits the evidence.
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.
The out-of-quota duty doubles
For quantities that exceed the available quota, the safeguard duty increases from 25% to 50% ad valorem.
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.
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.
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.
The European Commission presents proposal COM(2025) 726, based on the Steel and Metals Action Plan.
Political agreement between Parliament and Council and favourable vote in Parliament. The text is to undergo formal adoption and publication in the Official Journal.
The new mechanism enters into force and replaces the current measure.
The Commission is to adopt the implementing act specifying exactly what evidence importers must present for the "melted and poured" rule.
The concrete scenario
You import a steel product. What you check today and what you may be asked tomorrow.
- ✓Commercial invoice
- ✓Certificate of origin
- ✓Transport documents
- +Mill test certificate
- +Evidence of the country of melting and pouring
- +Supply-chain traceability
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.
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.
Outside the measure, for now. Check the CN codes periodically, the scope may be extended.
Origin undetermined. You face the worst treatment and customs delays.
You cannot demonstrate compliance. Risk of a 50% duty, reclassification or refusal at import.
● This is where the imported-product scenario fallsQuota exhausted. Import is possible, but with a 50% ad valorem duty.
Targeted product, real origin known and proven, available quota, hence import without additional safeguard duty and customs clearance without blocks.
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.
Why the melting and pouring rule
The logic of the measure, step by step, from the underlying problem to the burden of proof.
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.
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.
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 "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.
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.
The key message
For many companies, the challenge will not be the duty, it will be the evidence.
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.
Glossary
Click a term for its definition and its relevance to this measure.
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.
- ✓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?