Background

In our publication of 9 April 2026, we analysed the key implications of the proposed EU steel tariff-rate quota (TRQ) regime at a time when interinstitutional (trilogue) negotiations between the European Parliament, the Council, and the Commission were still ongoing.

On 24 June 2026, Regulation (EU) 2026/1384 of the European Parliament and of the Council, addressing the negative trade-related effects of global overcapacity on the Union steel market, was published in the Official Journal of the European Union. This Regulation replaces the existing EU steel safeguard measures, which are due to expire on 30 June 2026. The new regime enters into force on 25 June 2026 and applies from 1 July 2026.

However, a key issue remains unresolved. The quarterly administration and country-specific distribution of tariff quotas, including allocations to Free Trade Agreement (FTA) partners, have not yet been determined. It has been reported that the quarterly and country-level quota allocations will only be published on 30 June, just one day before they take effect. The uncertainty for importers is considerable: while steel prices are expected to rise, the precise impact will only become clear when the quotas – and how they are divided between different products and supplier countries – are published.

In this publication, we summarise the key features of the final EU steel measures, set out the staggered application dates, explain the tariff quota allocation framework (noting that the country-specific and quarterly allocation regime is yet to be confirmed), detail the melt-and-pour traceability requirements, and identify the key future deadlines and practical steps stakeholders should take now.

Key features of the published Regulation

The following is a summary of the substantive outcomes of the legislative process:

• The out-of-quota duty has been raised from 25% to 50% ad valorem and the total annual tariff quota volume is set at 18,345,922 tonnes, roughly half of current levels, broken down per product category and administered on a quarterly basis. With this structural tightening, importers should expect significantly more shipments to fall outside quota limits, triggering the higher duty rate.
• Melt-and-pour has been adopted as a transparency and traceability requirement only and does not serve as a basis for quota allocation at this stage. From 1 October 2026, importers must provide evidence (e.g., a mill test certificate) of the country where the steel was originally melted and poured. However, as early as 1 October 2027, the Commission will take melt-and-pour data into account for the country distribution of tariff quotas. By 30 June 2028, the Commission must assess whether melt-and-pour should become the full basis for quota allocation.
• Carryover of unused quotas is allowed during the first yearly period (1 July 2026–30 June 2027). After the first year, the Commission will decide, by implementing act, whether carryover continues, taking into account import pressure, average quota utilisation (especially where above 80%), and supply availability.
• The Commission must take into account the Union interest, including availability of supply and price increases affecting downstream industries, when adjusting quotas via delegated acts within defined floor and ceiling limits.
• Product scope reviews are staggered: by 31 December 2026, the Commission must assess whether to extend the product scope to cover specific CN codes not currently listed; by 30 June 2027, it must assess whether the scope should also cover products made of, or containing, a significant amount of steel (including downstream iron and steel products). Both of these assessments are directed at potentially expanding the product scope. From 30 June 2029 and every two years thereafter, the Commission must conduct further assessments of the product scope, which may result in either an expansion or a reduction, taking into account the wider situation of Union competitiveness and of the Union steel industry (including upstream and downstream actors and SMEs), as well as the Union’s common security and defence policy.
• Imports from Iceland, Liechtenstein, and Norway) are excluded from the tariff quota regime, while imports from Russia and Belarus are excluded from quota calculation as they remain subject to EU import bans.

Entry into force and staggered application dates

The Regulation enters into force on the day following its publication in the Official Journal, that is, 25 June 2026. Different provisions apply from different dates. The staggered application timeline is as follows:

25 June 2026 (entry into force)

• The Commission’s power to adopt implementing acts determining the type of evidence importers must provide to prove the country of melt-and-pour applies immediately.
• The elements the Commission must take into account when laying down the country distribution of tariff quotas are established.
• The Commission is empowered to adopt implementing acts on country distribution and, where appropriate, to apply bilateral safeguard measures.

1 July 2026 (general application)

• Tariff quotas are opened and the 50% out-of-quota duty applies.
• First yearly period: 1 July 2026–30 June 2027.

1 October 2026

• Importers must provide evidence of the country of melt-and-pour.

1 October 2027

• The Commission takes melt-and-pour data into account for the country distribution of tariff quotas.

Tariff quota allocation: Global and yearly

The quotas set out in Annex II to the Regulation are yearly and global, broken down per product category. No quarterly breakdown or country-specific allocation appears in the Annex itself, and no specific FTA partner quotas are provided at this stage.

Until the Commission adopts implementing acts establishing the country distribution and quarterly breakdown, quotas will be administered as published, on a yearly and global basis. Given that quarterly administration is expressly provided for in Article 3(2), the Commission is expected to publish the implementing act before 1 July 2026.

We understand that the EU is offering FTA partners more time beyond 1 July to formalise bilateral arrangements (for which parliamentary approval is required). The Commission has reportedly devised a three-column system:

• Column 1: grants all World Trade Organisation members 30% of historical import volumes.
• Columns 2 and 3: individual and competitive pool quotas available to FTA partners if they waive their FTA rights or pledge not to challenge the EU’s measures.

However, it remains unclear how this system will operate during the interim period, pending formal agreement with FTA partners.

Melt-and-pour traceability requirements

A separate implementing act will follow, setting out the specific documentary evidence importers must provide to demonstrate the country of melt-and-pour. Key points:

• A public consultation is currently running, with a deadline of 2 July 2026. Stakeholders can participate via the following link: EC consultation on melt-and-pour evidence.
• The first implementing act on the type of evidence required must be adopted by 31 August 2026.
• The obligation for importers to provide this evidence applies from 1 October 2026.

Key future dates

The Regulation establishes the following key milestones:

• 1 July 2026: stakeholder consultation on product scope.
• 31 August 2026: first implementing act on melt-and-pour evidence.
• 31 December 2026: assessment of amendments to product scope (specific CN codes).
• 30 June 2027: assessment of a broader product scope (downstream iron and steel products).
• 30 June 2028: assessment of melt-and-pour as a basis for quota allocation; first implementation report.
• From 30 June 2029, and every two years: further product scope assessments.
• From 30 June 2029, and every three years: effectiveness evaluation.

What to do next

With the Regulation now published, stakeholders – particularly importers – should:

• Verify product classification. Ensure correct CN code classification of your goods to determine whether they fall within scope, support any post-clearance claims, or establish that your product may be excluded from the regime.
• Assess origin correctly. Determine the non-preferential origin of your steel products, taking into account whether any processing operations in intermediary countries qualify as a sufficient change of origin. This is critical for understanding which country-specific quota your imports will draw from.
• Map melt-and-pour origins. Identify the country of melt-and-pour across your product portfolio and ensure suppliers can provide the required evidence (e.g., mill test certificates) from 1 October 2026.
• Participate in the public consultation on melt-and-pour evidence. The deadline is 2 July 2026; this is an opportunity to shape the implementing act on what evidence importers must provide.
• Build in-quota vs. out-of-quota cost models. With the duty gap now at 50%, the financial impact of falling outside quota is substantial.
• Stay tuned for the quarterly allocation implementing regulation, which is expected to be adopted imminently and will determine how quotas are distributed by country and by quarter in practice.

Reed Smith’s international trade team continues to monitor developments closely. Please do not hesitate to reach out to our team for tailored advice on how these measures affect your operations.