- The European Parliament proposes an extension of the CBAM-product list to include downstream products such as metals and metal products; machinery, electrical equipment and instruments; and transport equipment and other manufactured goods.
- As of 1 October 2026, importers of steel need to provide a Mill Test Certificate (or equivalent) in their customs declaration.
- As of 25 September 2026, tariff-rate quotas with minimum-price thresholds will be in place for imports of selected steel products from China, Japan, South Korea, Türkiye, the United Arab Emirates, and other countries.
Currently, there are a number of regulatory developments that particularly impact businesses which import steel products into the European Union (EU). In this article, we briefly summarise the latest updates on the Carbon Border Adjustment Mechanism (CBAM), the EU steel regulation, and the EU safeguard measures on selected steel products.
1. The European Parliament proposes an extension to the scope of CBAM-products as well as a tightening of anti-circumvention rules
CBAM has been fully in force since 1 January 2026. In its current form, CBAM applies to 569 products of aluminium, cement, electricity, fertilisers, iron and steel, and hydrogen.[i] On 17 December 2025, the European Commission published a proposal to extend this list of CBAM-products to 749 from 1 January 2028 onwards.[ii]
On 12 June 2026 and on 15 September 2026 respectively, the European Council and the European Parliament published their proposed list of products. Importantly, these lists go well beyond the European Commission’s proposal and include many downstream products of
- Iron and steel products (CN chapter 72).
- Articles of iron and steel (CN chapter 73).
- Copper (CN chapter 74).
- Aluminium articles (CN chapter 76).
- Tools and cutlery (CN chapter 82).
- Articles of base metal (CN chapter 83).
- Machinery and mechanical appliances (CN chapter 84).
- Electrical machinery (CN chapter 85).
- Railway equipment (CN chapter 86).
- Motor vehicles (CN chapter 87).
- Optical, measuring and medical instruments (CN chapter 90).
- Furniture (CN chapter 94).
In addition to the extension of the CBAM-product list, the European Parliament proposes lowering the threshold that would qualify as a circumvention of CBAM. In a next step, the European Commission, the European Council, and the European Parliament will negotiate the final product extension list in their trilogue later this year. For a more detailed comparison of the proposals and an indication of which products are more or less likely to make it onto the final CBAM-product list, read our article here.[iii]
2. The European Commission defines transparency and traceability requirements for selected steel products
The majority of the iron and steel products that currently fall under CBAM also fall under the EU steel overcapacity regulation “aimed at addressing the negative trade-related effects of global overcapacity on the EU steel market” which entered into force on 1 July 2026.[iv] In a nutshell, this regulation reduces the overall volume of steel tariff-rate quotas (i.e. the quantity above which a tariff becomes applicable) by about 50% compared to 2024 and doubles the out-of-quota duty from 25% to 50%. In other words, tariffs will become applicable twice as quickly and be twice as high.[v]
In addition, the European Commission aims to enhance the transparency and traceability of steel products imported into the EU through the introduction of a ‘melt and pour’ requirement applicable as of 1 October 2026.[vi] From this date on, importing businesses will be required to declare in their customs declaration the country in which the steel has been melted and poured. This declaration needs to be supported by a Mill Test Certificate detailing the country of ‘melt and pour’ as well as the heat number of the imported steel. If such a Mill Test Certificate is not available, businesses may provide alternative evidence based on
- Invoices.
- Delivery notes.
- Quality certificates and clauses in implemented purchase orders or contracts.
- Long-term declarations from suppliers.
- Cost accounting and production documents.
- Customs documents from the exporting country.
- Commercial correspondence.
- Production descriptions.
As of 1 October 2027, these documents will only be accepted as complementary to the Mill Test Certificate, but no longer as standalone documents.
3. The European Commission imposes provisional safeguard measures on imports of selected steel products
While the steel overcapacity regulation outlined above applies to a variety of products, on 18 September 2026 the European Commission also imposed provisional safeguard measures on the import of grain-oriented electrical steel products (GOES, CN codes 72251100 and 72261100) and steel laminations and cores for transformers and inductors (SLCs, CN code 85049013).[vii]
As of 25 September 2026, and for 155 days (until 26 February 2027), tariff-rate quotas with minimum-price thresholds will be in place for imports from China, Japan, South Korea, Türkiye, the United Arab Emirates, and other countries.[viii] For steel products, the minimum price will be set between €2800 and €3400 per metric tonne within the quotas and at €3500 per tonne for volumes above the quotas.
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