EU Proof of the Country of Steel Melt and Pour Takes Effect on October 1: Why Should Procurement Contracts Lock In MTCs and Heat Numbers in Advance?
Beyond the origin of steel imports, the EU is adding evidence tied more closely to the steel mill's production process. Buyers need to obtain it before shipment, not try to supplement it during customs clearance.
Key takeaway
From October 1, when covered steel products enter the EU, buyers will need to prove where the steel was originally melted and poured, not only where the product was exported from.
The European Commission has clarified that imported products covered by the new steel rules must declare the country of “melt and pour” to customs and support the declaration with verifiable documents. The main evidence is a Mill Test Certificate (MTC), which should include the country of melt and pour and the corresponding heat number. A lack of verifiable evidence may result in the import being rejected.
Why does this change procurement contracts?
After steel is rolled, coated, processed, cut, or traded through a third country, the country of export, customs origin, and country of melt and pour may not be the same.
If buyers wait until customs clearance to request the MTC, common risks include:
- The supplier is not the original steel mill and cannot obtain a complete MTC;
- The heat number does not match the actual batch;
- The trader provides only an invoice and an origin declaration;
- The documents do not clearly identify the country of melt and pour.
What should be added to RFQs and POs?
| Document or field | Recommended requirement |
|---|---|
| Mill Test Certificate | Must correspond to the actual batch |
| Melt and pour country | State the country clearly |
| Heat number | Must match the goods and certificate |
| Supplier declaration | Explain the upstream steel source |
| Change notification | Give advance notice when changing the mill or material |
| Document retention | Define responsibility for retaining and supplementing evidence |
Four preparation steps for procurement teams
- Identify steel materials and steel-containing SKUs entering the EU that may be covered by the new rules;
- Ask suppliers whether existing MTCs include the country and heat number;
- Add the required evidence to the PO and shipping-document checklist;
- Conduct a document pre-review before the first shipment is loaded.
Why is “the supplier says it is Chinese steel” not enough?
The rules require evidence that customs can verify. Buyers need to turn a verbal statement into batch-level documentation.
Scope and limits
The new requirements apply to products covered by the relevant steel rules. Importers or customs brokers should confirm the specific CN and TARIC scope. This article does not replace a formal customs determination.
FAQ
Is melt and pour the same as origin?
Not necessarily. They may be different.
Is import impossible without an MTC?
The rules provide arrangements for alternative evidence during a specific period, but the information must still be verifiable.
What should buyers change first?
Start with the procurement-document checklist. Make the MTC, country of melt and pour, and heat number mandatory fields for review before shipment.