Kallanish Steel: EURANIMI questions mill certificate reliability for melt-and-pour

European stainless steel traders’ association Euranimi has questioned whether Mill Test Certificates (MTCs) are
sufficiently reliable to verify the country where steel was originally melted and poured. This comes as the
European Commission consults stakeholders on documentary requirements under the forthcoming EU Steel
Regulation, notes Elina Virchenko for Kallanish.

The Commission launched a four-week consultation from 4 June to 2 July to gather input from steel
producers, users, traders, importers, customs authorities and other stakeholders on the type of evidence
that should be required to demonstrate melt-and-pour origin. The feedback will support an implementing act
establishing traceability requirements under the new regulation.

Responding, Euranimi answered “no” to whether an MTC alone should be considered sufficiently reliable
evidence.

The association argues that an MTC merely describes a steel product and is not physically embedded in
the material itself. Once steel has undergone multiple processing stages and passed through service
centres, traders and other operators, no independent authority can directly verify whether the document
presented genuinely corresponds to the imported product.

Euranimi adds that MTCs may be adequate for statistical monitoring, where incentives to challenge or
manipulate declarations are limited. However, if access to tariff-rate quotas or exposure to the EU’s
proposed 50% out-of-quota tariff depends on such documents, their reliability becomes a much more critical
issue.

“Where exposure to a 50% tariff depends upon a declarative document that is intrinsically fragile, readily
modifiable or even falsifiable, importers should not underestimate the practical consequences,” the
association says.

It warns that reliance on MTCs could result in intensified customs scrutiny, divergent interpretations across
member states and years of legal uncertainty, potentially exposing importers acting in good faith to
significant financial risks.

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Kallanish
English
23 June 2026