Since 1 October, a missing line on a mill certificate can get a steel import refused. Many importers are still unaware of it. Let me explain what has changed, without jargon, and above all what you can check before your next shipment.
What changed on 1 October
The Regulation (EU) 2026/1384 replaced the former steel safeguard on 1 July 2026. It sets annual tariff quotas totalling 18,345,922 tonnes and raises the out-of-quota duty from 25% to 50%. Above all, it adds a new obligation: proving, at import, the country where the metal was melted and poured, the “melt and pour”.
The Implementing Regulation (EU) 2026/1963 specifies the evidence required, and it has applied since 1 October 2026. The reference document is the Mill Test Certificate. It must state two things: the country of melt and pour, and the heat number. If one is missing, supplementary documents are accepted: invoices, delivery notes, quality certificates, contractual clauses, long-term supplier declarations, production records or customs documents from the exporting country. With no certificate at all, those documents may serve as evidence on their own, but only until 30 September 2027.
The country is declared in the customs declaration, with dedicated TARIC codes, and customs carries out a documentary check. The text is blunt: no verifiable evidence, no import.
What I actually see in the files
The same steel coil now carries three regimes, each with its own chain of evidence: the quota and its 50% duty, CBAM, and melt and pour traceability. And all three are decided before loading.
The quota is allocated per quarter, first come, first served. The quarter that opened on 1 October is under way. Once a line is exhausted, the 50% duty applies whatever the origin, on top of any anti-dumping duties. When a quota is flagged as critical, a guarantee covering the full duty can be required when the declaration is lodged. For a company, that is cash tied up for weeks.
Proof of melting is the point that most often jams. The certificate from the last rolling mill does not always say which furnace melted the metal. As soon as there is an intermediate processing step, the heat number gets lost along the way. And without a compliant certificate, customs checks the substitute documents, which takes time and can delay access to the quota.
CBAM, finally. The reference price of certificates for the third quarter was published on 5 October: €82.32 per tonne of CO₂, the highest of the year. Emissions data and proof of melting come from the same party, the steelmaker. My advice: ask for both in the same conversation.
Five questions to ask before the next shipment
- Do your CN codes appear in Annex I of Regulation 2026/1384? And, separately, in Annex I of CBAM? The two lists do not overlap.
- Do your mill certificates state both the country of melt and pour and the heat number? One of the two is not enough.
- Is your supplier the steelmaker or a processor? In the second case, can the heat number be traced back to the furnace?
- Do your purchase contracts already require a compliant certificate, in the format that will be the only one accepted from 1 October 2027?
- Who, in your chain, passes the TARIC codes and documents to your customs representative, and who monitors the quota status before loading?
If you hesitate on any of these five answers, you are not alone. That is precisely where files get stuck.
How we work with you
Our job is to deliver a ready-to-lodge file before the goods arrive. For steel: review of mill certificates against Regulation 2026/1963, consistency check between invoice, origin, tariff classification and CBAM data, quota monitoring and preparation of the declaration elements. CTB Group steers customs compliance and governance; the lodging itself remains with the representatives appointed by the company.
We are based in Europe, less than an hour from the port of Antwerp-Bruges. When a file gets stuck, that proximity saves hours, sometimes days.
Two dates to note. On 20 October 2026, Parliament, Council and Commission hold the first political trilogue on extending CBAM to processed steel and aluminium products: screws, bolts, tubes, wire, metal furniture. And by 31 December 2026, the Commission must deliver a first assessment on adding further steel products to the quota regime. The scope is widening. Better to be ready beforehand.
Further reading
- Metals and steel (CBAM): our sector support
- CBAM 2026: what changes for European importers
- The new Union Customs Code is in force: six dates to put in your diary
And you, where do you stand?
Are your mill certificates already complete? Have you run into a difficulty with a supplier or a processor? Share it in the comments, your feedback feeds the next articles. And if you would rather talk it through, let us take thirty minutes together: Free first call (30 min).
Photo: Morteza Mohammadi, Unsplash.