Melt and Pour: Verify Steel Origin Evidence in Procurement

A steel distributor expects three coil deliveries for a German customer. The invoice and packing list agree, but the mill certificate shows a different heat number from the shipping schedule. The supplier calls it a typing error. This is where a reliable melt-and-pour review begins: what matters is the traceable connection between imported goods, heat, production location and evidence, not the number of PDFs filed. This guide sets out a workplace process for procurement, quality and customs teams. Its worksheets and approval stages are operational recommendations, not official forms. Sources were reviewed on 30 October 2026.

1. Establish the current requirement first

Implementing Regulation (EU) 2026/1963 has applied since 1 October 2026. Article 1(1) generally requires a mill test certificate showing the country of melt and pour and the heat number when importing product categories covered by Annex I to Steel Regulation (EU) 2026/1384. This is not a blanket statement about every metal object. The customs function must first establish the goods classification, relevant import date and current scope. Procurement should not replace that assessment with a supplier's claim that all steel receives identical treatment. Record the conclusion and the version of the rules used.

Melt and pour refers to the original location where raw steel or iron is produced in liquid form and then cast into its first solid state; the regulation also addresses remelting scrap. A trader's dispatch country does not answer that question. Nor does the location of the final rolling, cutting or packing operation automatically establish it. Keep melt-and-pour country, supplier address, dispatch country and other relevant origin information in separate fields. Never copy an existing country value into the melt-and-pour field merely because the system requires an entry. An unknown value must remain an unresolved question.

2. Distinguish three evidence routes

Keep other regulatory assessments explicitly open on the checklist: adequate melt-and-pour evidence does not automatically settle sanctions, customs origin, tariff quotas or CBAM requirements. Give each assessment its own status and responsible specialist. The Commission's explanation of the evidence rules describes the transparency requirement, not a universal import authorisation. A clear handoff is enough for the pilot: which question has this review answered, and which remains with customs or compliance? This prevents a complete document pack from being passed on as comprehensive legal clearance.

The first route is an appropriate mill test certificate, usually called an MTC, containing both required details. If the certificate lacks the melt-and-pour country or heat number, documents listed in Article 1(2) may supplement the missing information. Examples include invoices, delivery notes and production records. Where no MTC is available, the documents permitted by paragraph 3 may temporarily be considered as standalone evidence if they contain the country and heat number. That option runs until 30 September 2027. Under the current regulation, the standalone replacement route ends on 1 October 2027.

The word 'may' matters when planning the work: a supplier letter does not become adequate evidence simply because of its heading. The competent customs authority assesses the documentation. Article 2(1) requires documentary checks where supplementary or standalone alternative evidence is used. German Customs guidance on the new steel instrument also explains country and document codes and the consequences of missing suitable evidence. Allow time for questions and have the customs function determine current codes. A green procurement-system status is neither official acceptance nor a guarantee that customs will release the goods.

3. Build a record around a traceable goods allocation

Eight field groups are enough for a pilot: purchase order and line; product description and checked classification; supplier and issuing mill; shipment and package references; heat number; melt-and-pour country; evidence files and versions; review decision, owner and date. This is a recommended internal structure, not an exhaustive list of legally required particulars. Allocate multiple heats within one order line separately. A combined field saying 'various heats' removes the connection needed later. For partial quantities, add a traceable quantity reference so a certificate is not accidentally assigned to another shipment. Keep original files unchanged.

Goods identity comes from the chain, not an isolated certificate. Quality staff compare product, dimensions, mill and heat references across available records; logistics adds package and shipment information. Different descriptions require an explained, evidenced mapping. This resembles the procurement-to-accounting verification chain in distance selling, without importing that sector's product-specific requirements into steel procurement. Both workflows share one principle: someone processing an invoice must not silently resolve an outstanding technical identification question. Record unreadable pages, cropped attachments and missing continuation pages as specific gaps rather than treating the existence of an uploaded file as completion.

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4. Ask suppliers precise questions and assign owners

A useful supplier request identifies the order, line, shipment and relevant heat. Ask explicitly for the country of melt and pour, corresponding heat number and evidence connecting both details to the ordered goods. If there is no MTC, ask which records actually exist rather than requesting a generic assurance. The CBAM supplier-data request process offers a transferable communication method: a precise question, named contact, outstanding issues and a traceable answer. However, emissions information and melt-and-pour evidence remain different review subjects. A completed CBAM questionnaire does not automatically close a gap in an MTC.

Procurement obtains documents and follows up questions. Quality checks the material connection. Customs assesses scope, evidence route and declaration requirements. Logistics preserves the connection to the shipment actually arriving. Appoint a named case owner for those handoffs instead of treating a shared mailbox as an accountable person. The CBAM task matrix for steel imports helps identify recurring interfaces, but does not replace the separate technical decision on melt and pour. One person may perform several tasks in a small business. The record should still distinguish which question that person answered and in which capacity.

Also establish which legal entity imports, which merely intermediates and who deals with customs. The manufacturer, importer and distributor role matrix illustrates this issue in online retail; its product-safety rules are not the legal basis for this steel review. The transferable organisational question is whether contracting party, invoice recipient and responsible function align. An external customs representative needs complete information and an accessible decision-maker. Appointing a service provider does not make unresolved material data correct. Record who obtains missing information and who arranges technical clarification before the declaration proceeds.

5. Practise three cases with the team

Case one: the MTC identifies heat H471 and a melt-and-pour country, but the packing list says H417. The exercise is not to spot a typo; it is to establish an evidenced allocation. The team marks the case unresolved internally, contacts the issuer through a known channel and requests a traceable correction or explanation. It does not edit the third-party certificate itself. If a replacement is supplied, retain the original, explanation and revised version together. The second review records which discrepancy was resolved and whether other delivery lines are affected. Delivery pressure does not change the question.

Case two: a trader supplies two heats in one shipment but only one certificate. Review of the documented heat may be complete while information for the second remains missing. Create separate allocations and let customs assess what further handling is legally and practically possible. Do not mark the entire shipment reviewed because one document exists. Subsequent partial releases must retain the connection between quantities and heats. Warehouse identification and document records need the same separation; otherwise the traceability achieved in the office disappears the next time material is moved or allocated to another customer.

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Case three: no MTC is available in November 2026. The supplier offers an invoice showing the melt-and-pour country and heat number. That may fit the temporary alternative route, but it is not automatic approval. Customs reviews the specific case and allows for the authority's documentary checks. The team also records a procurement action for future shipments: the supplier should establish a workable MTC process in good time. The same case requires a different assessment after 30 September 2027. Training materials therefore need a version and review date, not a timeless green tick.

6. Connect approval, deputies and records

Use three understandable internal statuses: awaiting review, question outstanding and internally reviewed. The last status records reviewer, date and document version. It means only that the defined company review is complete. Official decisions and other import requirements remain separate. A deputy matrix for key personnel helps cover absences: the deputy needs access to the case, outstanding questions and relevant decision authority. A telephone number without access to the file is insufficient. Practise taking over an unresolved delivery when the usual owner suddenly becomes unavailable, including how the deputy identifies the next safe step.

The training record should show which task was actually practised. Record target role, legal reference date, case version, observed decision and any follow-up instruction. Passing a general multiple-choice quiz does not establish that someone can allocate two heats correctly to a shipment. For training records without spreadsheet chaos, the connection between person, content and outcome matters. Keep that learning record distinct from the import file: one records the exercise, the other the actual goods transaction. Determine access and retention for each purpose with the responsible specialists rather than inventing a single unsupported retention period.

7. Start with a bounded pilot

Choose one supplier, one product group and a small set of real, already available document packs for the pilot. Measure whether the team can establish the goods allocation, how many questions remain open and whether a deputy can understand the decision. Fast processing is not a quality measure if unresolved contradictions simply move downstream. After the pilot, correct the request template, responsibilities and filing structure before expanding. Discuss the transition to MTC-supported evidence from October 2027 with the supplier so that a temporary alternative does not accidentally become the permanently planned default.

Then integrate the learning needs into the company's training plan. The overview of mandatory training and evidence helps structure that work, but does not establish a special statutory annual melt-and-pour course. Useful review triggers include a rule change, a new supply route or repeated allocation errors. ConformBase describes a melt-and-pour course within its steel offering; at the review date, the offer page still accepts expressions of interest during final content review. It replaces neither customs advice nor assessment of a particular shipment. Success remains observable: another competent person can read the evidence chain and understand the decision.