Since 1 October 2026, an importer bringing covered steel into the European Union has to be able to show where that steel was melted and poured, and show it with a document that carries the heat number. The rule is short, it is already in force, and it has a one year grace period attached to it that most teams will only notice once it has expired.

The useful part, for anyone who manages suppliers rather than customs declarations, is that the document in question is one your organisation very probably already receives. Commission Implementing Regulation (EU) 2026/1963 did not invent a new certificate. It took a document the steel trade has used for decades and made it the evidence that clears a border. So this is not a data collection project. It is a filing and retrieval project, and those are cheaper.

This piece is written for the supplier quality and procurement side of that work: which document, from whom, stored where, retrievable by whom, and what to put in a purchase order this quarter so the question stops coming up.

The sentence that makes this worth an hour of your time

Article 2(3) of the Regulation is one line long:

Failure to declare the country of ‘melt and pour’ with appropriate verifiable evidence as defined under Articles 1 and 2 shall lead to a rejection of the import.

That is a supply interruption with a documentary cause. It is the kind of risk that is almost free to remove in advance and expensive to resolve at a port, which makes it a good candidate for the small amount of preventive work described below.

What the Regulation actually asks for

Two facts, in one document. Article 1(1):

At the moment of import into the Union, importers of products falling under categories listed in Annex I to Regulation (EU) 2026/1384 shall provide a Mill Test Certificate that includes the country of ‘melt and pour’ and the heat number of the imported steel.

Regulation (EU) 2026/1384 of 17 June 2026 is the parent instrument, addressing the trade effects of global overcapacity on the Union steel market. Its Annex I lists steel product categories identified by Combined Nomenclature codes: hot rolled sheet, cold rolled sheet, stainless products, bars, wire rod, tubes and pipes among them. If you import any of those, the rule is yours to satisfy. If you buy from an EU supplier who imports them, it reaches you as a document request and a lead time question, which is the distinction drawn out below.

“Melt and pour” has a precise meaning in the parent regulation. It is the original location where raw steel or iron is first produced in liquid form in a steel or iron making furnace and then cast into its first solid state. Not where it was rolled. Not where it was cut, coated, galvanised or formed. The furnace.

Two points are worth drawing out, because both are good news.

The Regulation names the Mill Test Certificate and does not define it by reference to any standard. There is no clause requiring a European certificate format. A mill in Korea, Turkey, India or Brazil that issues its own certificate carrying the country of melt and pour and the heat number has issued an acceptable document. You are not asking anyone to reissue paperwork in a new form. You are checking that two fields are present.

The Commission chose this document precisely because it is already in circulation. Recital 9 explains that the Mill Test Certificate is the document “most widely recognised as the primary means of evidencing the country” and is “already being requested when exporting steel to some other non-Union countries.” The regulatory ask and the existing commercial practice point the same way, which is a more comfortable position than most compliance work starts from.

The one year window, and the better way to spend it

Article 3 sets the clock:

This Regulation shall enter into force on the day following that of its publication in the Official Journal of the European Union. It shall apply as from 1 October 2026. However, Article 1(3) shall apply from 1 October 2026 to 30 September 2027.

Article 1(3) is the flexible route. Where no Mill Test Certificate can be provided, eight other document types may be accepted on their own, as long as they carry the country of melt and pour and the heat number:

(a) invoices; (b) delivery notes; (c) quality certificates and clauses in implemented purchase orders or contracts; (d) long-term declarations from suppliers; (e) cost accounting and production documents; (f) customs documents from the exporting country; (g) commercial correspondence; or (h) production descriptions.

Recital 12 is explicit about why: a one year allowance lets economic operators progressively adjust their practices. The Commission has given the trade twelve months of tolerance on purpose.

Here is the part worth saying plainly. The standalone route expires. A purchase order clause does not. The temptation is to use the year as cover, defaulting to delivery notes and supplier declarations because they are easier to get, and to arrive at 30 September 2027 having built a process that stops working the following morning. The better use of the same twelve months is to spend them making the Mill Test Certificate arrive automatically, and to keep the Article 1(3) list in your back pocket for the handful of shipments where it genuinely does not.

After 30 September 2027 those eight document types are still useful. They stop being standalone evidence and become complementary evidence, which is what Article 1(2) provides for when a certificate exists but is missing one of the two fields. That is a real and permanent role for them. It is just not a substitute for the certificate.

The reconciliation nobody has run yet

Most organisations affected by this already hold the document. What they do not have is the document in the shape the declaration needs. Running these two columns against each other is the whole exercise, and it usually takes an afternoon.

What the quality file holds	What the declaration needs
A certificate per supplier, filed by vendor	A certificate per heat, retrievable by shipment
Filed on receipt, opened at audit	Available at the moment of customs declaration
Owned by quality or goods receipt	Needed by customs, trade compliance or the broker
Checked for chemical composition and mechanical properties	Checked for country of melt and pour and heat number
Good enough as a PDF in a folder	Needs the melt and pour country as a declared value, via TARIC document codes
Covers the material grade	Covers this consignment of this material
Kept because the standard asks for it	Kept because the border asks for it

The last two rows are where the work is. Article 2(2) states that the country of melt and pour is declared by means of TARIC document codes, which means it is not enough for the certificate to exist somewhere in your building. Somebody has to read a value off it and put that value in a field, per consignment, on time. Your customs team or broker will have the current code values; they change and they are not worth copying into a blog post.

That is a handoff between two functions that, in most mid-sized manufacturers, have never needed to speak to each other about a document. Quality holds it. Customs declares it. Neither owns the gap. This is the same structural problem as a supplier notification that nobody opens, pointed at a different pair of desks, and it responds to the same fix: name the owner of the handoff, not just the owner of each side. If your evaluation and compliance records already support cross-department collaboration, and your audit trail records who received which document and when, this is a small configuration job rather than a new process.

Why this obligation is a different shape from the others

Every supplier data obligation covered on this site so far attaches at one of two levels. Some attach to the company: certificates, policies, headcount, the certificate transition records you keep per vendor, and most of what sits in supplier master data today. Some attach to the product or the site, which is why a supplier register organised purely by vendor struggles with them, and why the supplier, site and part data model is worth building before a regulation forces the issue.

The heat number is a third level, below both. It identifies a batch of liquid steel from a single furnace charge. One purchase order can span several heats. One heat can be spread across several purchase orders and several customers. It is the finest grain of supplier data that any EU instrument has yet asked a buyer to hold.

And it has a second property that makes it genuinely new: the heat number is created by your supplier’s supplier. You almost certainly do not buy from the mill. You buy from a service centre, a stockholder, a distributor or a parts maker, and the certificate you need was issued one or two tiers upstream of your contract. The document has to travel down the chain to reach you, which means your direct supplier’s job is not to produce the information but to pass it through intact.

That distinction matters commercially, because it changes the tone of the request. You are not asking a distributor to generate data they do not have. You are asking them to forward a document that came with the coil. Framed that way, the request is reasonable, cheap for them to satisfy, and much more likely to be met. A supplier portal that lets them upload the mill document against the purchase order, once, removes most of the remaining friction. Request design is the single biggest driver of whether supplier data arrives at all, which is covered at length in what actually lifts supplier response rates.

It also sets a clear standard for what counts. A buyer-published supplier specification from the drive technology manufacturer Dellner Bubenzer states the position in one line: “Only inspection certificates issued by the original manufacturer are allowed.” A distributor’s own restamped summary of a mill certificate is a different document from the mill certificate. Worth knowing before you accept one.

Two positions to be in, and only one of them is yours

Work out which one applies before you do anything else. It takes a spend report and an import list, and no supplier contact at all.

You are the importer. You bring covered steel or covered steel products into the Union yourself. The evidence obligation is yours, the declaration is yours, and the rejection risk under Article 2(3) is yours. Your job is to make the certificate arrive with the goods, every time, and to make the melt and pour country reach whoever files the declaration.

Your supplier is the importer. You buy from an EU service centre or an EU parts maker who imports the raw material. The obligation sits with them. What reaches you is a document request and, occasionally, a lead time conversation, because a supplier who cannot evidence melt and pour cannot clear the material they were going to make your parts from. This is worth a line in your supplier risk view rather than a project: an EU supplier heavily dependent on imported steel in the Annex I categories now has a documentary dependency that did not exist in September 2026. It is exactly the sort of signal third party risk scoring should pick up and most models do not yet carry.

Many organisations are in both positions at once, for different parts. That is normal, and it is the usual reason a role recorded against the vendor rather than against the buying relationship goes quietly out of date. The useful record is per material per sourcing route, not per supplier.

The lever that works better than a chase

The cheapest way to make a document arrive reliably is to stop asking for it and start owing something for it.

The Dellner Bubenzer specification mentioned above does exactly this, and publishes it. It states that the inspection certificate “is part of the scope of supply”, that it “must be received by the time of delivery at the latest”, and then adds the sentence that does the actual work: “invoices cannot be settled until the APZ 3.1 is received.” The same document requires parts to be physically marked with the heat number, by steel stamp, engraving or etching pen, so the material and its certificate cannot drift apart on a shop floor.

None of that is novel, and none of it needs a regulation to justify it. It is simply a purchase order term that converts a recurring chase into a condition both sides understand from the start. If you write one thing into your terms this quarter, write that: the mill test certificate carrying country of melt and pour and heat number is part of the scope of supply, due no later than delivery, and a condition of invoice settlement.

A clause like this is only as good as the record behind it, which is the argument made in full in writing supplier quality agreement clauses you can actually measure. One clause, one record, one owner, one review point. A certificate requirement with no named field to store the result in is a wish.

Published stockholder guidance is worth reading alongside your own terms. The UK stockholder West Yorkshire Steel describes a 3.1 inspection certificate as one issued by “the manufacturer of the steel” which “will show the cast/heat number, material size or thickness and the chemical composition”. That is the shape of the document to expect, described by someone who issues them daily.

A ten field certificate record

If you are going to store this properly, store it so the four questions below can each be answered with one filter. The fields are a starting point, not a benchmark, and most of them already exist somewhere in your systems, usually spread across supplier information records, goods receipt and a shared drive.

Field	Why it earns its place
Heat number	The identifier everything else hangs from, and the one the Regulation names
Country of melt and pour	The declared value. Not the country of shipment, not the country of rolling
Issuing mill, with plant name and location	The certificate is issued by a named works, not by a company
Certificate type and reference	What you received, so a restamped summary is visibly not a mill certificate
Direct supplier	Who you bought from, which is usually not the mill
Sourcing route	Mill direct, service centre, stockholder, parts maker. Changing route changes the document path
Material grade and specification	What the quality function cares about, and the reason the file already exists
Purchase order and consignment reference	The link that makes the certificate retrievable by shipment rather than by vendor
Document received date and received by	The evidence that the clause in your terms is being honoured
Melt and pour value declared, with date	Closes the loop between the document and the declaration

The four questions that record has to answer in one filter each:

1. For this consignment, which heats are in it and where was each melted and poured?
2. For this heat number, where is the certificate and who received it?
3. Which suppliers delivered covered material in the last quarter without a mill certificate?
4. Which of our EU suppliers source Annex I material from outside the Union, and would therefore feel a documentary delay before we do?

The third question is the one that tells you whether your purchase order clause is actually working. The fourth is the one that nobody is asking yet.

Doing this without a project

A sensible first pass, in order, with no supplier contact until step four.

1. Get the covered list. Ask your customs team or broker for your import lines falling in the Annex I categories of Regulation (EU) 2026/1384 over the last twelve months. This is a report they can already run.
2. Find the certificates you already hold. Sample ten of those lines and try to retrieve the mill certificate for each by consignment, not by supplier. How many you find, and how long it takes, is the real measure of where you stand.
3. Check the two fields. On the certificates you did find, confirm the country of melt and pour and the heat number are both present and legible. Missing fields are what Article 1(2) complementary evidence exists for, and knowing which suppliers have the gap is more useful than knowing the count.
4. Write the clause. Put the certificate into your purchase order terms for covered material: part of the scope of supply, due by delivery, condition of settlement. Then tell suppliers, with the reason, before the first invoice is held, and fold the requirement into onboarding and qualification for new ones so it never needs retrofitting.
5. Name the handoff owner. One person accountable for the melt and pour value reaching the declaration, on both sides of the quality to customs boundary.
6. Set the review date. Put 30 September 2027 in the calendar with one question attached: are we still relying on Article 1(3) anywhere, and for which suppliers?

Six steps, and five of them involve no new software and no supplier burden. If your supplier records currently live in spreadsheets, the retrieval test at step two is usually the moment that becomes obvious, which is a separate conversation covered in moving supplier management off spreadsheets.

What this does not do

Worth being clear, because adjacent claims are already circulating.

It does not make you responsible for your supplier’s declaration. Where your EU supplier is the importer, the evidence obligation is theirs.

It does not replace the material verification your quality function already performs, nor does it change what your supplier compliance records need to hold for every other regime. Chemical composition and mechanical properties are still why the certificate matters technically. The Regulation adds two fields to the list of reasons to keep it.

It does not require a specific certificate standard. The Regulation names the Mill Test Certificate and leaves the format alone.

It does not tell you the TARIC document codes. Article 2(2) says the declaration is made by means of them, and the current values belong to your customs team, not to a blog post.

And it does not, on its own, give you traceability. A certificate retrievable by consignment plus a heat number marked on the material is traceability. A PDF in a folder named after a vendor is a record that you once received a document.

The reusable part

Strip out the steel and the structure generalises, which is why this is worth reading even if you never buy a tonne of the stuff.

A document your organisation already receives acquired a second purpose, in a second function, with a different retrieval pattern and a hard date attached. Nothing was added to the collection burden. Everything changed about where the document has to be reachable from. That happens repeatedly, across regimes, and the organisations that absorb it cheaply are the ones that stored the purpose of every field alongside the field, which is the argument in collect once and report many times. The EUDR supplier data plan is the same shape with a different commodity list, and automotive teams will recognise the pattern from the material traceability their customers already demand, discussed in the IATF 16949 scorecard guide and in our notes on automotive supplier management.

The second reusable piece: when a document is created upstream of your direct supplier, your request is a forwarding request, not a data request. Say so. It is true, it is easier to agree to, and it gets better results.

Frequently asked questions

When did this start?

Commission Implementing Regulation (EU) 2026/1963 of 28 August 2026 applies as from 1 October 2026. The flexible standalone evidence route in Article 1(3) applies from 1 October 2026 to 30 September 2027.

Which products are covered?

Products falling under the categories listed in Annex I to Regulation (EU) 2026/1384, which lists 28 steel product categories by Combined Nomenclature code, including hot rolled and cold rolled sheet, stainless products, bars, wire rod, tubes and pipes. Confirm your own lines against the CN codes with your customs team rather than by product name.

What exactly is the country of melt and pour?

The original location where raw steel or iron is first produced in liquid form in a steel or iron making furnace and then cast into its first solid state, as defined in Regulation (EU) 2026/1384. It is not the country of rolling, coating, forming or shipment.

What if the mill certificate does not show the heat number?

Article 1(2) allows complementary evidence where the certificate is missing the country of origin or the heat number, drawing on the same list of document types as Article 1(3). That route is permanent. The standalone route, where there is no certificate at all, is the one that ends on 30 September 2027.

Is an EN 10204 certificate what is being asked for?

The Regulation names the Mill Test Certificate and does not define it by reference to a standard, so it does not require any particular certificate type. In European practice the document usually arrives as an inspection document issued by the steel manufacturer, and published stockholder guidance describes that document as carrying the cast or heat number, dimensions and chemical composition. Check that your supplier’s certificate carries the two fields the Regulation names, whatever it is called.

We buy finished parts, not steel. Does this apply to us?

It applies where the products you import fall in the Annex I categories. If you buy finished parts from an EU supplier who imports the material, the obligation sits with that supplier, and what reaches you is a documentary dependency in their supply chain worth tracking in your supplier risk records.

Will suppliers push back on this?

Less than you might expect, because most of them are being asked by other customers too, and because the document already exists upstream. Recital 9 of the Regulation notes the certificate is already requested when exporting steel to some non-Union countries. The requests that fail are usually the ones that ask a distributor to create information rather than forward it.

What is the single highest value thing to do first?

Try to retrieve the mill certificate for ten recent consignments, by consignment. Whatever that exercise reveals is your real starting position, and it takes an afternoon.

---

If you are tightening up how supplier documents are requested, stored and retrieved across several regimes at once, EvaluationsHub keeps certificates, declarations and evidence against the supplier, site and material records they belong to, with the request and follow up handled for you. Book a walkthrough or start with a focused pilot on one category.