Key data
| Regulation | Commission Implementing Regulation (EU) 2026/1963 of 28 August 2026 |
|---|---|
| Publication | 31 August 2026 |
| Entry into force | 28 August 2026 |
| Affected parties | European importers of steel products, especially cast and forged steel |
| Category | European Regulation |
| Year | 2026 |
| Official source | OJ:L_202601963 — EUR-Lex |
If you import steel into the European Union, you have a new documentary obligation that is already in force. The Commission Implementing Regulation (EU) 2026/1963, published on 31 August 2026 in the Official Journal of the EU, determines what specific evidence you must present to customs authorities to prove in which country the melting and casting of the steel you introduce to the European market took place.
The purpose of the regulation is to close a common route for circumventing trade defence measures—such as anti-dumping tariffs or safeguards—through which steel manufactured in countries subject to restrictive measures was "rerouted" through third countries to conceal its true origin.
What does this regulation establish?
The regulation establishes the types of evidence required to prove the country of melting and casting of imported steel. This is relevant because the origin of steel in customs matters is not determined solely by the last country of dispatch, but by the place where substantial transformation took place: melting and casting.
The specific obligations it introduces are:
- Collection of specific documentation proving the country of melting and casting of the steel.
- Presentation of such documentation to customs authorities at the time of import.
- Guarantee of origin traceability throughout the supply chain, including supplier contracts.
The regulation does not specify in its summary text a closed list of specific documents (such as steel mill certificates, foundry delivery notes or manufacturer declarations), so it is recommended to consult the full text of the regulation in the official source to know the exact details of accepted documents.
Context is key: this measure strengthens origin controls in the steel sector to prevent the EU's trade defence measures—anti-dumping tariffs, countervailing duties, safeguards—from being circumvented through origin triangulation.
Economic and operational impact
The impact is not just documentary: it has direct economic consequences for any company importing steel.
| Scenario | Consequence |
|---|---|
| Complete and correct documentation presented to customs | Import without additional surcharges |
| Incomplete or missing documentation | Application of additional tariffs (anti-dumping, safeguards or others) |
| Documentation not accepted by authorities | Retention of goods at the border |
The increased administrative burden is inevitable: importing companies will need to establish internal processes to request, verify and archive origin documentation for each transaction. This involves time, resources and coordination with foreign suppliers who, in many cases, are not accustomed to this level of documentary requirements.
For SME importers, the impact is proportionally greater: they do not have specialized customs departments and rely more on customs agents or external managers, which can increase operational costs per transaction.
Who does it affect?
- European importers of steel products, especially those working with cast and forged steel.
- SME steel importers that purchase from third-country suppliers (Asia, Latin America, countries under EU anti-dumping measures).
- Manufacturing companies that import steel as raw material for their production (automotive, construction, machinery, capital goods).
- Traders and distributors of steel products operating as intermediaries in the import chain.
- Customs agents and logistics operators managing the clearance of steel goods on behalf of their clients.
- CFOs and purchasing directors of industrial companies with international steel procurement.
Practical example
Imagine a Spanish company manufacturing metal structures that imports steel coils from a supplier based in Turkey. Until now, the supplier issued a commercial invoice and a Turkish certificate of origin, and the transaction passed customs without incident.
With Regulation (EU) 2026/1963 now in force, the company must prove not only that the steel left Turkey, but that the melting and casting was actually carried out in Turkey and not in a third country under anti-dumping measures (for example, China). If the Turkish supplier cannot provide such documentation—because it actually buys steel billets from Chinese manufacturers and only rolls them in Turkey—the Spanish importing company faces customs applying additional tariffs or retaining the shipment.
The solution: review the contract with the Turkish supplier and include a clause requiring them to provide documentation proving the country of melting and casting in each shipment, before the goods leave the country of origin.
What should companies do now?
- Review contracts with foreign steel suppliers and include the express obligation to provide documentation proving the country of melting and casting in each transaction.
- Audit the supply chain to identify which suppliers may have difficulty proving the actual origin of melting and casting (especially if they operate in countries under EU anti-dumping measures).
- Consult the full text of the regulation on EUR-Lex to know exactly what documents are accepted as valid proof.
- Coordinate with the customs agent to update clearance procedures and incorporate origin document verification as a mandatory step before each import.
- Train the purchasing and logistics team on the new requirements, especially if they manage direct relationships with suppliers in Asia or countries with a history of circumventing anti-dumping measures.
- Establish a document archive per transaction that allows you to demonstrate compliance in the event of a customs inspection. Non-compliance can result in additional tariffs or retention of goods at the border.
Frequently asked questions
What documents must I present to prove the country of melting and casting of steel?
Regulation (EU) 2026/1963 determines the types of evidence required, but the exact details of accepted documents are found in the full text of the regulation, available on EUR-Lex. In general terms, this is documentation proving that the melting and casting of the steel was carried out in the country declared as origin, such as steel mill certificates, manufacturer declarations or production chain traceability documents.
What happens if I do not submit the required documentation to customs?
According to the regulation, non-compliance can result in two direct consequences: the application of additional tariffs (such as anti-dumping tariffs or safeguard duties) or the retention of goods at the border. Both situations generate significant costs and delays for the importing company.
When did this obligation come into force?
Commission Implementing Regulation (EU) 2026/1963 entered into force on 28 August 2026, the date of its adoption by the European Commission. It was published in the Official Journal of the EU on 31 August 2026. The obligation is already enforceable.
Does this regulation affect only large importers or also SMEs?
It affects all European importers of steel products, regardless of size. The regulation expressly mentions that SME steel importers must review their supply chains and supplier contracts to ensure origin traceability. For SMEs, the administrative impact is proportionally greater as they do not have specialized customs teams.
Why does the EU now require proof of the country of melting and casting?
The objective is to prevent circumvention of trade defence measures such as anti-dumping tariffs or steel sector safeguards. A common practice consists of manufacturing steel in a country subject to restrictive measures and "rerouting" it through a third country to conceal its true origin. This regulation closes that route by requiring proof of where the substantial transformation of steel took place: melting and casting.
Official source
View complete regulation on official source
Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202601963