In its statement, Gerber Group recalled that under the EU Steel Regulation 2026/1384, importers will be required to provide information on the country of melt and pour for imported steel products starting from October 1, 2026. The European Commission must establish, by August 31, 2026, the rules specifying which documents will be accepted as proof of this information.
The company said the Commission's decision will determine whether the new system becomes a practical trade mechanism or a new bureaucratic obstacle, particularly for small and medium-sized importers and steel traders.
Gerber Group CEO Thorsten Gerber stated in the company's submission to the Commission that existing commercial documents, such as invoices, packing lists and Mill Test Certificates (MTCs), should be considered sufficient proof of "melt and pour" information. He argued that requiring new certificates for every customs declaration, inspections of production facilities or additional documentation would be disproportionate and unworkable for SMEs.
The statement also noted that, in cases where no Mill Test Certificate is available, such as for standard commercial products or mixed inventories, a simple self-declaration referring to the heat number should be accepted. Gerber Group added that this approach has been successfully applied in the United States for years without a mandatory document submission requirement.
Criticism of Commission's legal authority
Gerber Group argued that, through Article 4(2) of Implementing Regulation 2026/1457, the European Commission has exceeded its legal authority and violated the rules of origin established under the Union Customs Code.
Thorsten Gerber said the Commission is legally obliged to take the specific circumstances of SMEs into account and avoid imposing disproportionate administrative burdens, noting that both the European Parliament and the Council of the European Union made this intention clear during the drafting of the Steel Regulation. He added that Brussels should fulfill this obligation and stop acting in favor of large steel producers.
Warning over serious risks for SMEs
The company warned that excessive documentation requirements under the "melt and pour" regime would place SMEs without dedicated legal and compliance departments at a significant disadvantage. According to Gerber Group, supplier contracts would have to be renegotiated, small suppliers and mixed inventories could effectively be excluded from the market, customs procedures would face delays, and all of these changes would have to be implemented within a transition period of only two months. By contrast, the company argued, vertically integrated steel producers that fully control their supply chains would be largely unaffected by the new rules.
Based in Riegel am Kaiserstuhl, Germany, Gerber Group is a medium-sized stainless steel and aluminum trading company with operations in Germany, Italy, Asia and the United States. Led by founder and CEO Thorsten Gerber, the company has been serving small and medium-sized businesses engaged in trading and manufacturing for more than 20 years.
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