Melt-and-Pour Meets CBAM: The 1 October 2026 Steel Evidence Deadline Importers Keep Missing

In about two weeks, every importer of covered steel into the EU has to answer a question most supply chains were never set up to answer: where was this steel melted?

From 1 October 2026, Regulation (EU) 2026/1384 - the EU steel overcapacity regulation - requires importers of covered steel products to evidence the country of "melt and pour". Not the country of shipment. Not the country of non-preferential origin. The country where the liquid steel was first cast.

Meanwhile CBAM is asking your supplier a different question about the same shipment. And the answers do not substitute for each other.

The short version

• Regulation (EU) 2026/1384 has applied since 1 July 2026, replacing the steel safeguard measures that expired on 30 June 2026.
• The out-of-quota duty rose from 25% to 50% ad valorem, and it stacks on top of any anti-dumping or countervailing duties already in place.
• Annual tariff-rate quotas run 1 July to 30 June, totalling roughly 18.3 million tonnes - an average cut of about 47% in duty-free volumes across 26 product categories compared with the previous safeguard quotas.
• From 1 October 2026: melt-and-pour evidence is required, in practice a mill test certificate identifying where the steel was melted. The Commission consulted in June 2026 on what evidence is acceptable.
• From 1 October 2027, melt-and-pour data are expected to feed quota allocation more actively, with an evaluation by 30 June 2028 on whether it becomes a primary criterion for quota access.

Two regimes, one shipment, two different questions

This is the point worth internalising, because teams keep conflating the two.

	Steel Regulation (2026/1384)	CBAM
The question it asks	Where was this steel melted and poured?	How was this steel made, and what emissions are embedded in it?
Unit of analysis	Country of first solidification	Installation, production route, tonne of CO₂e
Evidence that proves it	Mill test certificate, heat/cast number, mill identification	Installation identifier, production route, verified emissions data or a default value
What it gates	Quota access and duty rate	Certificate obligation and declaration accuracy
If you cannot prove it	You face the out-of-quota duty, or the goods do not clear as expected	You fall back to default values, with their built-in mark-up, or you cannot file a defensible declaration

Same supplier. Same mill. Often the same piece of paper in the same email thread. But a mill test certificate that names a melting country tells you nothing about the production route or the embedded emissions, and a CBAM communication template full of emissions data may never state where the steel was melted.

Why customs origin will not save you

The most common assumption - "we already track origin, so we're covered" - is the one that fails.

Non-preferential customs origin is determined by substantial transformation. Melt-and-pour is determined by where the metal was first cast. These can diverge, and in global steel they routinely do.

A worked example. Slab is melted and cast in Country A. It is shipped to Country B, where it is hot-rolled into coil. Depending on the product and the applicable rules, the rolling may confer non-preferential origin in Country B. Your customs declaration says Country B. Your melt-and-pour evidence has to say Country A.

Now add the third layer: for CBAM, what matters is the installation in Country A that actually produced the crude steel, its production route, and its emissions - plus the precursor cascade behind it. Three regimes, three answers, one coil.

This is precisely the territory CBAM's anti-circumvention provisions were written to police, and the melt-and-pour requirement extends the same logic into trade defence. Routing steel through an intermediate country to change its paperwork is getting harder on both fronts simultaneously - which is, fairly clearly, the intent.

The landed-cost stack, honestly

It is tempting for anyone in the CBAM world to present carbon as the dominant new cost. In 2026, on steel, that is not true, and pretending otherwise damages credibility with procurement.

The stack looks like this:

1. Base price - negotiated.
2. Anti-dumping / countervailing duties - where applicable, unchanged by the new regulation but not displaced by it.
3. Tariff-rate quota position - in-quota, or 50% ad valorem out-of-quota.
4. CBAM certificate cost - embedded emissions × CBAM factor × certificate price, less any carbon price already paid abroad.

In 2026 the CBAM factor is 2.5% and the certificate price sat at €75.36/tCO₂e for Q1 and €75.28 for Q2. Run that against even a high-emissions tonne of steel and the carbon layer is real but modest this year.

A 50% out-of-quota duty is not modest. It is immediate, it is large, and it applies to the full customs value.

So the honest framing for 2026 is: the trade-defence layer dominates your landed cost today; the carbon layer dominates your cost trajectory. The out-of-quota duty is a cliff you avoid by managing quota timing. The CBAM cost is a ramp you manage by changing what you buy and from whom - and it climbs every year to 2034 as free allocation is phased out.

Both belong in the same sourcing model. Neither should be modelled without the other.

Quota timing is now a CBAM-adjacent decision

Quotas open annually on 1 July and run to 30 June. When duty-free volume is cut by roughly half and the penalty for missing it doubles, the incentive to import early in the quota window becomes very strong - and so does everyone else's.

That produces predictable behaviour: front-loading at the start of the quota period, exhaustion risk for the categories and origins where quota is tightest, and a scramble for whatever remains.

Here is the connection most teams miss. If quota pressure pushes you to switch origin mid-year, you have not just changed a duty calculation. You have changed the installation, the production route, and therefore the embedded emissions behind your CBAM declaration - possibly from a supplier with verified actual data to one where you will be stuck with default values. A quota-driven sourcing switch is a CBAM data event.

Model them together, or you will optimise the duty and quietly worsen the carbon number.

Collect it once

The operational recommendation is straightforward: do not send your suppliers two separate data requests.

Melt-and-pour evidence and CBAM installation data come from the same place - the mill - and both are naturally keyed to the same identifier: the heat or cast number. One supplier request, one document set, one linkage:

• Heat/cast number as the primary key
• Mill identification and melting country (steel regulation)
• Installation identifier and production route (CBAM)
• Emissions data or explicit reliance on defaults (CBAM)
• Mill test certificate as the underlying document, retained

If your supplier contracts do not already oblige delivery of mill test certificates with melting country identified, that is a contract amendment worth making now rather than in October. Our clause-by-clause CBAM contract drafting guide covers the CBAM side; the melt-and-pour obligation slots into the same documentation and warranty clauses.

One more operational note: CBAM obligations attach at release for free circulation, and so does your quota position. Both regimes turn on the same customs moment, which makes your choice of customs procedure a lever on both at once.

What to do before 1 October

• List your covered CN codes and confirm which of your steel imports fall under Regulation (EU) 2026/1384.
• Ask every steel supplier now for mill test certificates identifying the melting country, for current and forward orders. Two weeks is not long for a mill in a different time zone.
• Check whether melt country ≠ customs origin anywhere in your book. Where it does, flag those lines for closer handling.
• Confirm your broker's readiness to present the evidence at declaration, and agree the format.
• Map heat numbers to CBAM installation data so the two datasets are linked rather than living in separate spreadsheets.
• Re-run your landed-cost model with the 50% out-of-quota duty and your realistic quota position, alongside CBAM cost.
• Set a quota monitoring routine for your top categories and origins.

The steel regulation and CBAM were written by different parts of the Commission for different purposes. They have converged on the same point in your process: the moment a supplier tells you what they made, how, and where. Answer both questions with one request, and October is administrative. Answer them separately, and you will be doing this twice a year, forever.