Europe’s ‘melted and poured’ rules on steel will be made clear by September: Van Bael & Bellis
Speaking at the Eurometal Steel Day and the 10th YISAD Flat Steel Conference in Istanbul on Tuesday April 8, Di Gianni detailed the recent regulations introduced by the European Commission.
The Commission intends to tighten current steel trade defense measures, improve regulations for the prevention of carbon leakage and provide affordable clean energy to support the steel industry, according to a draft version of the European Steel and Metals Action Plan.
One of the most important points in the plan is the ‘melted and poured’ rule, which basically will mean that the Commission will be able to trace the origin of steel exported into Europe.
For example, if hot-rolled coil is exported to Europe from Turkey but the slab used to produce the HRC was from China, the Commission may impose the import duty for slab of Chinese origin. The exporters and buyers will be required to trace the production origin of the end-materials.
Such investigations into the origin may go back retrospectively by three years, Di Gianni said in his presentation to the conference.
Conference delegate Ahmet Soybaş, partner at Soybaş Steel, asked how the origin of hot-dipped galvanized coil would be traced.
For instance, a galvanizer may buy Turkish HRC, galvanize it, and then export it to Europe. The end-producer cannot know the origin of the slab, Soybaş said, because it bought HRC as substrate. Di Gianni said that the European Commission would investigate why the galvanizing was done in Turkey. “Was it in order to [avoid] duties on Chinese HDG? That is the question the Commission will ask,” Di Gianni said.
Tayfun İşeri, coordinator at Colakoglu Metallurgy, asked how end-users such as automotive exporters would know the location of melting. “How will this be traceable?” he asked.
He also said that if a producer used locally produced slab to make HRC for export to Europe, and then used imported slab for HRC to be consumed locally, how would the Commission be able to know the difference in the final materials?
Di Gianni said that details on all these points were not clear yet but the Commission was expected to announce details by the end of the third quarter of 2025.
He added that the Commission was also planning to impose limits on scrap exports from Europe by September.
EU origin rule could reshape trade, impact Turkey
If implemented by the EU, the “melted and poured” rule would mark a departure from existing trade flows, posing serious challenges for Turkish processors and global supply chains, Fabrizio Di Gianni said at this week’s EUROMETAL Steel Day and 10th YISAD Flat Steel Conference in Istanbul attended by Kallanish.
The EU is considering a shift to a “melted and poured” regime, where origin is linked to where the steel was first melted. In this case, steel melted in China and later transformed in Turkey would still be considered Chinese for trade defence purposes.
Traditionally, origin has been based on the last substantial transformation – for example, if Chinese hot rolled coil was processed in Turkey, the final product would be considered Turkish.
On the sidelines of the conference, a market participant said: “If this measure is implemented, targeting Chinese-origin inputs, it could reshape trade flows and force Turkish slab and HRC buyers to rethink their sourcing strategies. This could be the next black swan event – we need to watch closely, as it may come before year-end.”
The introduction of the “melted and poured” rule would aim to more accurately trace the true origin of steel products. While current anti-dumping and anti-subsidy measures apply to direct imports, they can be circumvented by routing semi-finished goods through third countries. These goods undergo further processing before being shipped to the EU, thereby avoiding trade duties.
The European Commission wants to close this loophole and strengthen trade defence tools. If applied, the new rule would remove the possibility of altering a product’s origin through minimal processing and provide clearer traceability. The goal is to ensure that duties apply based on the actual source of steel production – especially when that source benefits from non-market conditions and excess capacity that distort global trade.
Meanwhile, a trading source noted that with existing uncertainty over increasing global tariffs, anti-dumping measures, and EU tariff-rate quotas on finished steel, demand for semi-finished products like slab and billet is rising. “We’re preparing for increased semis intake into the EU,” the source said, noting that preference will likely shift towards electric arc furnace semis, especially with CBAM enforcement beginning in the EU in 2026.
Fabrizio Di Gianni: EU taking aggressive stand to protect industry
At the EUROMETAL Steel Day & YISAD Flat Steel Conference held at Istanbul Marriott Hotel Asia on Tuesday, April 8, in cooperation with SteelOrbis, Fabrizio Di Gianni, partner at law firm Van Bael & Bellis, talked about the recent developments in EU trade policy, its Clean Industrial Deal and its Action Plan on Steel and Metals.
Mr. Di Gianni gave details regarding the recent dramatic changes in the EU’s trade policy. He noted that, even though current trade defense instruments continue to play a crucial role, upcoming legislation is equally important for Turkish steelmakers to maintain trade relations with the EU, to keep the possibility of exporting and penetrating the European market, and to gain a strategic advantage.
One of the aspects of the trade policy is the Clean Industrial Deal (CID), which aims to decarbonize energy-intensive industries such as steel and aluminum that are the foundation of industrial growth.
Mr. Di Gianni said there are three main topics in the CID that are of importance to Turkish companies.
One are the Clean Trade and Investment Partnerships (CTIPs), which complement the free trade agreements. Under the CTIPs, clean energy supply chains and strategic trade relations will be strengthened. It will also prioritize clean technologies, renewable energy, and decarbonization.
Secondly, the European Commission (EC) will simplify the Carbon Border Adjustment Mechanism (CBAM) to reduce the burden on the industry, while ensuring carbon-intensive imports are regulated and global decarbonization is promoted. One of the most important changes to the CBAM will be the removal of about 90 percent of importers, mostly small and medium enterprises, from the scope of the mechanism. In addition, the EC will extend the scope of the CBAM to downstream products and to indirect emissions.
Lastly, the CID indicates the possibility of adjusting current tariffs to ensure a level playing field and the strengthening of trade defense instruments such as antidumping and countervailing duties, as well as safeguard measures to cope with the risk of trade frictions, especially as a result of the recent US measures.
Regarding the Action Plan on Steel and Metals, Mr. Di Gianni pointed out that the most crucial aspects of the plan for Turkish companies are the prevention of carbon leakage, and the promotion and protection of European industrial capacities. Therefore, in order to prevent carbon leakage, the threshold for quarterly emissions under the CBAM will be reduced to 50 percent from 80 percent.
The EC is also considering the possibility of extending the CBAM to certain downstream products to eliminate the risk of circumvention. Moreover, as the EC is taking a more aggressive stand, it will change its methods for the investigation. It would normally require evidence that imports from a certain country caused a major material injury.
With the new changes, it will proactively open investigations based on the threat of injury. Furthermore, the commission will launch stronger market surveillance. Also, there might be some modifications to the lesser duty rule, under which antidumping duties are set on the basis of the lowest level between dumping and injury margins. In the meantime, with the introduction of the melted and poured principle, origin will no longer be determined by the country of processing but by the country where the steel was originally melted.
The Van Bael & Bellis official concluded his presentation by saying that, by the third quarter of this year, the commission will consider limiting scrap exports. This could limit access to EU scrap for third-countries recyclers and may reduce the availability of scrap for export, he noted.
