From 1 October 2026, anyone importing steel products listed in Annex I of EU Regulation 2026/1384 must state the country of melt and pour in the customs declaration and substantiate it, primarily with a Mill Test Certificate (MTC) showing the heat number. Without verifiable evidence, Dutch Customs may refuse the import. The key action for Dutch manufacturing this week: establish per supplier who the importer is, request the certificate, and contractually secure delivery of documents, warranties and cost allocation.
What is actually happening
The EU Steel Regulation (EU) 2026/1384 entered into force on 25 June 2026 and has applied since 1 July 2026 as the successor to the steel safeguard that expired on 30 June 2026. According to the European Commission, the regulation sets duty-free quotas at 18.3 million tonnes, with a 50% duty on out-of-quota imports and a melt-and-pour regime to enhance transparency. Dutch Customs reports that the out-of-quota rate thereby doubles from 25% to 50% and that available import quotas have been cut by 47% compared with the previous measures.
The melt-and-pour element applies from 1 October 2026. Dutch Customs states that from that date you must prove the country of melt and pour of your steel with a mill certificate (MTC) showing two data points:
- the country of melt and pour, and
- the heat number of the imported steel.
Which evidence is accepted is set out in Implementing Regulation (EU) 2026/1963, adopted by the Commission on 28 August 2026 according to Eurometal and Baker McKenzie. According to Evofenedex, melt and pour means the location where raw steel or iron is first produced in liquid form and cast into its first solid state; that is not necessarily the country where the material was rolled, bent or processed.
Alternative evidence. If the MTC lacks either data point, Customs may assess complementary evidence: invoices, delivery notes, quality certificates or clauses in purchase orders/contracts, long-term supplier declarations, cost-accounting and production records, customs documents from the exporting country, commercial correspondence or production descriptions. These documents must contain both the country of melt and pour and the heat number.
Transition period. From 1 October 2026 to 30 September 2027 these documents may, according to Evofenedex, also serve on their own where no MTC exists. From 1 October 2027 they will, according to SteelOrbis and Eurometal, only count as a supplement to an MTC; Eurometal phrases this more cautiously as "the Commission may then limit the admissible evidence". Plan your contracts on the strictest scenario: an MTC per shipment from October 2027.
Declaration. The melt-and-pour data are included in each declaration via TARIC document codes. A Northern Irish industry body published provisional guidance with codes Y376–Y387 for the country of melt and pour and C131 (MTC) to C139 for evidence; confirm the current code list with your customs broker.
Consequence if missing. Evofenedex states that Customs may refuse the import if the country of melt and pour is not demonstrated with appropriate and verifiable evidence. Eurometal reports that the Commission treats this as non-compliance with the regulation's transparency requirements.
Structural drivers
Melt and pour is not a stand-alone formality but the first phase of a trajectory. According to Baker McKenzie, from 1 October 2026 the requirement is purely a transparency and traceability obligation, and from 1 October 2027 melt-and-pour data will begin to feed into the country allocation of quotas. Anyone documenting carelessly now is building a data history on which quota access will later be based.
The quota allocation itself is laid down in Implementing Regulation (EU) 2026/1457. According to CMS, free trade partners receive 50% of the annual volume, largely based on historic trade volumes, while the other 50% is open to all WTO members; quotas are administered quarterly. Crowell points out that the 50% duty stacks on top of existing anti-dumping or countervailing duties. Eurometal reports that imports from Iceland, Liechtenstein and Norway remain outside the quota system.
There is also overlap with existing rules. According to Customs Support, for the Russia sanctions (Article 3g of Regulation 833/2014) an MTC is already used, based on Commission guidance, as evidence of the origin of steel inputs. Customs Support notes that one complete MTC can serve both regimes, but that a certificate showing a different melt country in the sanctions file than on the customs declaration creates exposure under both regimes. In addition, CBAM already requires embedded-emissions data for iron and steel. For the buyer this means three data streams per steel shipment (sanctions origin, melt and pour, embedded emissions) that trace back to the same supplier and the same heat number.
Who is directly affected
Direct (first order): every party acting as importer for goods whose CN code falls within Annex I of Regulation 2026/1384, regardless of supply route. In Dutch practice these are:
- steel stockholders and service centres sourcing coil, plate, sections or tubes from outside the EU;
- manufacturers (machine building, offshore, construction and installation engineering, equipment building) buying outside the EU on EXW, FCA, FOB or CIF terms and therefore acting as declarant or importer themselves;
- customs brokers in Rotterdam, Amsterdam and Antwerp who file the declarations and must be able to rely on the supporting evidence.
Castings and processed parts: whether a casting, forging or semi-finished product is in scope depends solely on its CN/TARIC code against Annex I. The sources consulted mention no separate regime for castings. Check this per code; do not assume a product is out of scope because it is "a component".
Probably not directly affected:
- buyers sourcing exclusively from EU producers, or via an EU distributor that handles the import itself; the declaration obligation lies with the importer;
- buyers on DDP terms, where the supplier (or its representative) imports.
These groups may still be affected: when switching to a non-EU source, when Incoterms change from DDP to FCA/DAP at contract renewal, or indirectly when their distributor adjusts stock or prices because of refused shipments. Company exposure: not yet calculated — link spend and supplier data per CN code.
The second-order effect
The chain below is Orbecta analysis (level C), not an established market outcome.
Event: from 1 October an MTC with melt country and heat number is the standard at import. → First order: importers must collect documents per shipment; shipments without verifiable evidence may be refused. → Second order: traders mixing steel from several melt shops or processing it via third countries (for example steel rolled or coated in another country) may struggle to document per heat number. This could lead to a shift of non-EU purchases towards suppliers with demonstrably complete traceability, and to extra costs for documentation, clearance delays and port demurrage. → Condition: this effect becomes plausible when a substantial share of non-EU supply runs through traders unable to pass on a mill certificate, and when Customs assesses alternative evidence strictly. → Procurement indicator: share of shipments with a complete MTC, clearance lead time at your broker, number of checks/refusals, and demurrage invoices.
A second chain runs through price. According to SMM, European steel producers have announced price increases for late Q4 2026, citing tighter domestic spot availability and higher coking coal costs; the mills expect buyers to restock more from November as earlier import quotas are exhausted. That is a seller expectation, not an established fact. Meanwhile a Benelux service centre reported HRC orders at €720–735 per tonne delivered in early August (Kallanish via Eurometal), while offers of up to €750 per tonne were not accepted and even the target of around €740 per tonne delivered was seen as unworkable by several buyers. If melt-and-pour friction makes import alternatives effectively more expensive or slower, this could strengthen the negotiating position of EU mills — but whether that happens depends on quarterly quota utilisation and actual demand.
Dutch procurement impact
Dutch industry is also running at a higher pace. The Nevi PMI fell slightly in August from 54.4 to 53.8 but stayed above the growth threshold of 50; new export orders rose at the fastest rate in more than four years and input prices are still rising relatively fast. Growing order books at suppliers increase the risk that documentation requests slip down their priority list — all the more reason to secure them contractually.
Contract clauses
Include at least the following in new and renewing purchase contracts for steel and steel-containing components of non-EU origin (have the wording legally reviewed):
| Clause | Content |
|---|---|
| Documentation obligation | Per shipment an MTC with country of melt and pour and heat number, delivered digitally no later than shipment; from 1 October 2027 without exception. |
| Traceability through processing | For rolled, coated, bent or cast material: linking the end product to the original heat number, also where processing took place in another country. |
| Warranty and indemnity | Supplier warrants the accuracy of melt-and-pour data and indemnifies against duties, penalties, storage, demurrage and replacement costs in case of refusal or correction. |
| Right of suspension | Right to suspend payment or acceptance as long as complete evidence is missing. |
| Source-change notification | Prior written notice of any change of melt shop or melt country. |
| Cost allocation and Incoterm | Explicitly who is importer, who bears any out-of-quota duty and whether it is included in the price. |
| Audit and information right | Access to underlying production/certificate documentation, aligned with CBAM and sanctions information. |
Note: a fixed price does not protect absolutely. Contracts with surcharges, price-review or hardship clauses may still pass on costs of quota exhaustion or duties.
Supplier conversations
Ask not only whether a supplier provides an MTC, but whether it shows the melt country and heat number. The Royal Metaalunie advises (via Metaalnieuws) contacting suppliers now and checking exactly that. For long-term relationships a long-term supplier declaration can be a supplement, but not the basis after the transition period.
Sourcing mix
Suppliers are not interchangeable. Compare alternatives on: completeness and consistency of MTCs, direct mill relationship versus trading, qualification lead time for new material, quota position of the melt country, CBAM emissions data and logistics connection to Rotterdam/Antwerp or the Rhine corridor. A benchmark on these criteria comes before a shortlist.
Claim defence
Expect suppliers and distributors to cite the new rules as grounds for Q4 surcharges. Test such a claim on four points: (1) what share of their purchases is non-EU and falls under Annex I; (2) what are the actual extra documentation costs; (3) is the quota for their origin country demonstrably exhausted; (4) how does the requested increase compare with a named HRC benchmark (index, reference date, delivered or ex-works). An increase that cannot be substantiated on these points is a negotiating opener, not a given.
Budget and risk
Record a scenario in your category plan in which part of the non-EU shipments is delayed or refused, and calculate the impact on safety stock and demurrage. An indication of a BOM effect requires the steel share per product; that is product-specific and cannot be derived from the sources.
What is certain and what is still uncertain
What is certain: Regulation 2026/1384 has applied since 1 July 2026 with quotas of 18.3 million tonnes and a 50% out-of-quota duty; from 1 October 2026 the country of melt and pour must be declared and proven, primarily with an MTC showing the heat number; evidence rules are in Implementing Regulation 2026/1963; the transitional arrangement for alternative evidence runs until 30 September 2027; without appropriate and verifiable evidence Customs may refuse the import.
What is still uncertain: how strictly Customs will assess alternative evidence in the first months and how many pre-clearance checks will take place; which products exactly fall under Annex I after the product scope review for which the Commission launched a consultation on 30 July 2026; how melt-and-pour data will influence quota allocation from 1 October 2027; and whether the announced Q4 increases by EU mills will be accepted by the market.
What to watch: percentage of shipments with a complete MTC per supplier; clearance lead time and demurrage at your broker; quota utilisation per quarter and origin country; North-West European HRC benchmark (delivered vs ex-works) relative to €720–735 per tonne; supplier claims referring to the Steel Regulation.
What you can do now
- This week — procurement + customs broker: have your broker confirm, for all current and planned non-EU steel shipments per CN code, whether they fall under Annex I and which document code will be declared. Then decide per shipment whether delivery proceeds or is held until the evidence is complete.
- This week — steel category manager: ask every non-EU supplier and every trader in writing for a sample MTC showing melt country and heat number, plus confirmation that it will accompany each shipment. Flag suppliers that do not deliver within ten working days as a risk for the transition period.
- This month — procurement + legal: include the clauses from the table in current renewals and Q4 tenders; record per contract who is importer and who bears any out-of-quota duty. Then decide whether DDP or FCA terms offer the best risk profile per supplier.
- This month — category manager + EU distributor: ask your EU distributors what share of their stock is non-EU and how they secure melt and pour, and require substantiation with benchmark, reference date and quota status for any Q4 price increase. On that basis decide on partial fixing, indexation or phased offtake — after comparison, not in advance.
- This quarter — compliance + procurement: harmonise per supplier the data streams for melt and pour, CBAM and Russia sanctions at heat-number level, so that every shipment is covered by a complete MTC before 1 October 2027.
How Orbecta supports
With Contract Intelligence you screen existing steel and component contracts for missing documentation, indemnity and Incoterm provisions. Claim Check tests announced Q4 increases against benchmark, reference date and quota status, and Warroom Prep prepares supplier conversations on certificates and cost allocation.
Sources
Primary source: Dutch Customs (Douane) — Proving the country of melt and pour for steel mandatory from 1 October (Dutch-language) — 22 September 2026 Primary source: European Commission, DG Trade — EU Steel Regulation: Commission launches targeted consultation on first product scope review — 30 July 2026 Operational confirmation: Evofenedex — Q&A: How to comply with the obligations of the new EU Steel Regulation (Dutch-language) — date not specified on page Operational confirmation: Evofenedex — Commission clarifies evidence rules for steel imports (Dutch-language) — 3 September 2026 Additional context: Baker McKenzie Global Import Blog — EU: European Commission adopts proposal for new trade defence regime for steel imports with application from 1 October 2026 — 22 September 2026 Additional context: CMS — Unprecedented EU Steel Regulation targets global overcapacity — July 2026 Additional context: Crowell & Moring — EU Steel Overcapacity Regulation: New Permanent Measure in Force from 1 July 2026 — July 2026 Additional context: Eurometal — EU clarifies rules for proving the "melt and pour" country for steel imports — September 2026 Additional context: SteelOrbis — EU outlines evidence requirements for steel 'melt and pour' declarations — September 2026 Additional context: Manufacturing NI — EU Steel Melt and Pour Provisional Guidance — date not specified on page Additional context: Customs Support — Mill Test Certificates for EU Steel Imports – From Guidance to Law — September 2026 Additional context: Metaalnieuws — Steel imports: stricter origin requirements from 1 October (Dutch-language) — 16 September 2026 Additional context: Eurometal (Kallanish) — European coil price trends unclear before September — August 2026 Additional context: SMM (news.metal.com) — European Hot-Rolled Coil Prices Rise as Steelmakers Target Q4 Price Increases — September 2026 Additional context: Vraag & Aanbod — Nevi PMI: exports pick up, Dutch industry keeps growing (Dutch-language) — September 2026
Orbecta analysis based on the sources above.