According to EURANIMI’s analysis, once a melt-and-pour rule, based on the country where the steel is originally melted and cast, is implemented, the EU would effectively lose almost all of its external supply options. Only 12 countries worldwide have melt-and-pour stainless steel capacity. Due to sanctions, bilateral trade limits, high tariffs, low export availability, or structural constraints, EURANIMI argues that the only realistically viable supplier for the EU would be South Korea, specifically POSCO. This would leave the EU dependent on a single external producer.
EURANIMI also stressed that the melt-and-pour criterion may look traceable on paper, but in practice it is not verifiable. Mill certificates submitted at customs are PDF documents not physically tied to the product and can be duplicated easily. Basing millions of euros in duties on documents that cannot be reliably authenticated would carry major risks.
The association highlighted that stainless steel production involves multi-stage processes often performed in different countries. Throughout hot rolling, cold rolling, cutting and service-center operations, origin information can be mixed, and true melt-and-pour origin cannot be scientifically identified once processing takes place.
EURANIMI warned that such a system would create 27 different interpretations across 27 EU member states, leading to inconsistent customs practices. Importers could face arbitrary or unpredictable assessments due to doubts over documentation, undermining legal certainty within the EU.
Mill certificates are meant for technical accuracy, EURANIMI said. Turning them into origin-proof documents for commercial advantage would damage the sector’s quality-assurance system and negatively affect thousands of manufacturers.
The association argued that the stainless steel industry is already protected by anti-dumping, anti-subsidy and anti-circumvention measures, and that a melt-and-pour rule would add no additional value—only market contraction and legal uncertainty. EURANIMI urged the Commission to abandon the melt-and-pour criterion entirely. If not, the rule should be postponed until a universally recognised, fraud-resistant traceability system exists.
EURANIMI also pointed out that the U.S. SIMA system acknowledges this limitation: melt-and-pour data is used only for monitoring, not for determining duties.
Board Member Christophe Lagrange stated: “An unverifiable rule is not a rule. Melt-and-pour in its current form would turn customs declarations into a paper trap and the stainless steel market into Russian roulette.” He added that for some actors, the true goal may be to pressure importers and undermine confidence in non-EU mill certificates.
Board Member Rob Greve emphasised: “Legal certainty is not a technical detail, it is the foundation of the market. Before implementing melt-and-pour, the Commission must be sure it is practically verifiable.” Noting the extremely limited number of melt-and-pour countries, Greve warned that the rule would effectively leave the EU dependent on a single external producer: “Is that really the intended policy outcome?”
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