German stainless steel and aluminium trader Gerber Group has called on the European Commission to simplify the documentation requirements for the forthcoming "melt and pour" rules, arguing that excessive administrative obligations would place a disproportionate burden on small and medium-sized enterprises (SMEs).
The appeal was submitted as part of the Commission's consultation on implementing Regulation (EU) 2026/1384, which will require importers to prove the country where imported steel was melted and poured from October 1, 2026. The Commission is expected to define the acceptable forms of evidence by August 31.
Existing documents should be sufficient
In its submission, Gerber Group argues that existing commercial documents—including invoices, packing lists and mill test certificates (MTCs)—should be accepted as proof of origin.
According to CEO Thorsten Gerber, introducing new standalone certificates, mandatory mill audits or additional documentation requirements for every customs declaration would create unnecessary complexity for SMEs.
The company also proposes allowing importers to submit a simple self-declaration linked to the relevant heat number in cases where no mill test certificate is available, such as for standard commercial products or mixed inventories. Gerber noted that a comparable approach has been used in the United States for several years.
Concerns over administrative burden
Gerber Group further argues that excessive documentation requirements would force many SMEs to renegotiate supplier contracts, reduce sourcing flexibility and increase customs-related delays, while larger, vertically integrated steel producers would be less affected due to their greater control over supply chains.
The company also criticizes the European Commission's approach, claiming that the implementing rules should better reflect the EU's obligation to avoid disproportionate administrative burdens for smaller businesses.
Headquartered in Riegel, Germany, Gerber Group supplies stainless steel and aluminium products to small and medium-sized enterprises through operations in Germany, Italy, Asia and the United States.
Source: Gerber Group, Photo: Fotolia
