Steel importers into the European Union must now manage melt-and-pour origin records alongside CBAM emissions information, adding a separate documentation requirement to the customs and purchasing process for covered steel products.
From 1 October 2026, covered steel imports must identify the country where the steel was initially melted and poured. Guidance published by PwC Switzerland on 24 September identifies the mill test certificate and heat number as central records for establishing this information.
Alternative evidence can be used during a transition period running until 1 October 2027, according to PwC. After that date, such evidence is intended to supplement rather than replace the required mill documentation. Supplier declarations, invoices and production records can contribute to the supporting evidence chain.
Origin records and CBAM emissions data remain separate
The melt-and-pour requirement forms part of the EU steel trade framework, rather than the methodology used to calculate embedded emissions under CBAM.
A document establishing where a particular heat of steel was produced does not, by itself, determine the material’s verified carbon intensity. Likewise, an emissions report does not automatically resolve every question concerning customs origin.
The two compliance processes nevertheless intersect operationally because both require importers to connect delivered material with reliable information originating further upstream in the supply chain, potentially beyond the trader named on the sales invoice.
Processed steel creates additional traceability requirements
A service centre purchasing processed steel may therefore require documentation extending beyond a declaration supplied by its immediate vendor. The records must maintain the connection to the original production documentation through subsequent cutting, coating, resale or other transactions.
This makes consistency between procurement, customs and sustainability records important. Differences involving producer identity, batch references or quantities can be addressed more readily before delivery than after a customs or carbon-related query.
For steel suppliers, the documentation required by European customers consequently extends beyond the characteristics of the finished product. They must be able to maintain a defensible origin trail while separately supplying the emissions evidence required for the EU customer’s CBAM obligations.
