Steel Melt and Pour: The Evidence Importers Must Hold

The change, and who it bites

From 01/10/2026, an importer moving steel into Northern Ireland has to prove where that steel was melted and poured. Documents, not assertions. Commission Implementing Regulation (EU) 2026/1963, adopted on 28/08/2026 and applying from 01/10/2026, sets out which evidence counts and what happens when it is absent.

HMRC has since added the document codes that carry the position onto a Customs Declaration Service entry. Codes C131 to C139 and Y376 to Y387 went into Appendix 5A on 27/09/2026 for steel melt and pour requirements in Northern Ireland. The same appendix changed again on 22/10/2026.

The codes are keyed by whoever makes the declaration. The evidence sits in the importer's own records, and so does the liability. That gap is the whole story.

What the regulation requires

The requirement applies to products in the categories listed in Annex I to Regulation (EU) 2026/1384, the Steel Regulation. Article 1 sets a three-tier evidence test.

Primary evidence. A Mill Test Certificate provided at the time of import, showing the country of melt and pour and the heat number of the imported steel.

Complementary evidence. Where the certificate shows one of those two elements but not the other, customs may accept a further document to supply the missing element. The permitted types are invoices, delivery notes, quality certificates and clauses in implemented purchase orders or contracts, long-term supplier declarations, cost accounting and production documents, customs documents from the exporting country, commercial correspondence and production descriptions.

Standalone evidence. Where no Mill Test Certificate can be provided at all, those same document types may be accepted on their own. They must show both the country of melt and pour and the heat number.

Two further provisions decide the commercial consequence. Article 2(1) obliges customs authorities to carry out documentary checks on the information and the supporting evidence. Article 2(3) provides that where the country is not declared with verifiable evidence behind it, the import is rejected.

Then read the dates again. The standalone route in Article 1(3) runs only from 01/10/2026 to 30/09/2027. The widest version of the evidence list is the version that expires. An importer leaning on purchase orders and commercial correspondence this year needs a mill certificate route written into supply contracts well before next autumn. The fallback disappears while the obligation stays.

What to check in your own declarations

This is a records question dressed as a declaration question. Five checks, in the order they usually find something.

1. Coverage. Take every affected commodity moving into Northern Ireland since 01/10/2026. Does each item carry a country-of-melt-and-pour code? Is the declared country the one your paperwork supports?
2. Retrievability. Pick ten entries at random. Try to produce the Mill Test Certificate for the heat number on each, from your own records, today. If the answer is the supplier will have it, you do not have it.
3. Completeness. Where a certificate is on file, does it show both the country and the heat number? If one is missing, which document filled the gap? Is that document filed against the entry, or sitting in somebody's mailbox?
4. Contractual reach. If the evidence lives with the supplier or the mill, what in the purchase terms obliges them to produce it two years from now? By then the relationship may have cooled or the trader may have changed hands.
5. Code currency. Appendix 5A moved again on 22/10/2026. Document code Y501 was added. Y138 was amended to remove the requirement to declare the Document ID where an exemption is claimed using status code 'XW', though a Document Reason is still required. Declaration templates and standing instructions written before that date may now be wrong in a way that passes quietly.

Point five is the one importers consistently underrate. Appendix 5A changed twice inside a month. Nobody tells you when a template drifts out of date.

How post-clearance audit addresses it

A border rejection is loud and expensive. It also gets fixed the same week. The slower exposure is the entry that cleared: code declared, goods released, evidence never obtained. Documentary checks under Article 2(1) look backwards, and so does routine post-clearance verification. By then the consignment has been consumed, the supplier has moved on, and the importer is the party on the hook for what was filed on its behalf. That is the point clearance is no longer the finishing line was written to make.

Post-clearance audit closes that distance. It compares what was declared against what the records can support. Working through full entry-level data, MyCustomsInfo® identifies affected items where a melt and pour code was declared with no retrievable evidence behind it, affected commodities declared with no code at all, and entries still running on superseded code instructions. CustomsPlus® then builds the evidence pack. Where an amendment is warranted, it is the client's own licensed customs broker who makes it. MyCustomsInfo® finds and evidences the position. The broker files it.

That division matters commercially as well as legally. An importer who can produce the evidence trail on demand argues from a different position entirely. CustomsPlus® has recovered and repaid £3.2M for clients in 2026 to date, and in one matter an assessment of £4.4M was reduced on the strength of the underlying records. Both outcomes came from documentation, not from argument. Treated properly, customs compliance is a financial control, not a technical task.

What to do this quarter

Steel moving into Northern Ireland now faces an evidence standard tighter than most importers' filing practice, with a fallback route that closes in eleven months. The declarations are already being made. The question is whether the records behind them would survive being asked for. Importers already working through the EU customs reform action plan should fold this into the same exercise.

A compliance review takes your own entry data, tests it against the current requirements and shows you where the evidence is thin while there is still time to obtain it from the mill. If steel reaches Northern Ireland anywhere in your supply chain, have that review before the standalone evidence route closes.

Book a Compliance Review and bring your last quarter of entries.