SMR Stainless Club: Euranimi pushes back against melt-and-pour over supply and legal uncertainty

The EC’s plan to use melt-and-pour origin rules in the new steel regime is drawing strong criticism from stainless distributors, who fear supply distortions and loss of legal certainty writes Kateryna Samoilenko for SMR Stainless Club.

The “melt-and-pour” criterion was included in the EC’s October 2025 proposal of the new steel measure, which will replace the current steel safeguards in 2026. It determines the origin of imported steel based on where the liquid steel was first melted and cast. This marks a clear change from the current “substantial transformation” rule, which assigns origin to the country where the product underwent its final significant processing and took its finished form.

While the EC presents the use of the “melt-and-pour” rule as a way to improve traceability and fight circumvention, Euranimi, an association of mill-independent metal distributors, argues that, in the case of stainless steel, it cannot be reliably verified. Additionally, it would squeeze non-EU supply, and would turn customs into a paperwork trap, creating legal uncertainty.

Only twelve non-EU countries melt and pour stainless steel. However, Euranimi believes that under the “melt-and-pour,” this would translate into only one practically viable non-EU source. In its view, India would fall out of the “general” regime once an EU-India FTA with its own rules of origin takes effect. Other suppliers are constrained in different ways:

– Russia is sanctioned;
– China and Indonesia are targeted by various anti-dumping, anti-subsidy and related trade-defence measures;
– Taiwan is an active exporter to the EU, but only a few companies there melt stainless steel themselves, while most focus on rolling imported semi-finished products.
– the U.S, Japan, Brazil and South Africa mainly serve their domestic or regional markets;
– Canada and Ukraine are marginal producers.

Based on that elimination process, Euranimi warns that the melt-and-pour rule could concentrate EU imports almost entirely on South Korea, leaving POSCO as the only producer with sufficient volume to serve the market. Such an outcome would contradict the EU’s stated objectives on diversification and resilience. This does not mean that these countries could not export to the EU (except for Russia), but, in Euranimi’s view, they would not, in practice, form a reliable large-scale supply base under the proposed regime.

Euranimi also highlights that melt-and-pour traceability entirely depends on documentation rather than physical identifiers, making it easy to manipulate and impossible to verify once the material leaves the mill. “Mill certificates are self-declaratory PDFs, not physical identifiers linked to a coil or sheet. They circulate independently of the steel they describe and can easily be altered or reused, especially in today’s AI-enabled environment,” Euranimi stated. In such a system, the declared origin can be “adjusted” according to quota availability, turning a sensitive origin into a safer one on paper only.

Euranimi also notes that flat stainless products are covered by a dense web of anti-dumping, anti-subsidy and anti-circumvention duties on China, Indonesia, Taiwan, India, Turkey and Vietnam. At the same time, the association highlights a contradiction in semi-finished products. While melt-and-pour would restrict finished stainless products melted in China or Indonesia, slab imports from those same origins remain unrestricted, deepening EU mills’ dependence on third-country feedstock.

The association also warns of a regulatory environment where 27 customs authorities can interpret the rule differently, and some of them can start rejecting certificates based on suspicion rather than verifiable evidence. ”When a 50% duty is at stake, that would mean the collapse of legal certainty for EU importers with no way to distinguish between genuine certificates, those tampered with by suppliers seeking to stay competitive, and those resulting from mutually agreed “origin adjustments,” Euranimi stated.

Euranimi proposes abandoning the melt-and-pour method for stainless steel and maintaining the substantial transformation rule. If the EC nevertheless proceeds, Euranimi calls for postponing implementation until a universally recognised, scientifically validated traceability system exists.

They also suggest alternative improvements that remain within the current framework, including more precise product definitions, clearer substantial-transformation criteria in anti-circumvention cases, and reinforced controls on certificate acceptability.

Euranimi concludes that melt and pour offers “the illusion of tackling issues at their root” while risking market distortion, concentration of supply, and the erosion of legal certainty in a sector that is already comprehensively protected by existing trade defence instruments.

That view contrasts sharply with many producers, who have welcomed the measure as a way to shield the European market from the spillover of global overcapacity.

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SMR Stainless Club
English
16 November 2025