Steel suppliers to the European Union must now provide additional production-origin evidence, with new melt-and-pour documentation requirements applying from 1 October alongside existing CBAM emissions reporting.
The requirements are established by Implementing Regulation (EU) 2026/1963, adopted on 28 August, and apply to steel products covered by the relevant EU steel-market regulation.
The framework requires documentation identifying the country where the steel was melted and poured. Mill test certificates must contain that information together with the steel’s heat number. Transitional arrangements permit alternative evidence before the complete certificate requirement takes effect in October 2027.
Traceability requirements operate separately from CBAM
The new measures concern steel-trade traceability, rather than introducing a change to the CBAM methodology for calculating emissions.
For individual shipments, however, exporters and EU importers may need to maintain both origin-related documentation and carbon-emissions evidence. The two requirements therefore create overlapping operational work around the same transaction.
Suppliers operating multiple mills or processing locations need records that maintain a clear connection between the material delivered and the relevant production records.
Mill-level records become important for shipments
Gaps in melt-and-pour information can complicate customs clearance and delivery planning, including in cases where the shipment’s CBAM emissions calculation has already been completed.
Purchasing teams therefore need to establish that mill certificates and supporting documentation correspond to the steel actually supplied, rather than simply obtaining the additional documents as a procedural requirement.
The new evidence framework places greater importance on reliable mill-level documentation for steel suppliers serving the European market, while CBAM emissions reporting continues to operate under its separate regulatory requirements.
