CBAM,‘ Melt & Pour’, and the limits of traceability
Why on-site carbon verification cannot solve origin determination
Across Brussels, a growing political consensus is forming around a concept that appears simple and decisive: the introduction, for certain steel products, of a‘ melt and pour’ origin criterion- attributing origin not on the basis of the last substantial transformation, but on the place where the liquid steel was solidified.
By Christophe Lagrange, EURANIMI
The European Commission has floated it. EU Trade and Economic Security Commissioner Maroš Šefčovič appears favourable. Committees of the European Parliament have expressed support. Several Member States approve it. The Committee of the Regions has welcomed it. Only the Council has adopted a more cautious tone. At the same time, another narrative is gaining ground: CBAM will make this easier. Under the CBAM framework, non- EU installations wishing to maintain effective access to the European market must accept independent verification of their production data, with verifiers granted access to relevant facilities, systems, and records. In practice, this means that production processes and material inputs are audited in order to validate reported emissions. The reasoning appears straightforward. If verifiers already have access to production records and input data, if sourcing structures become more transparent, then establishing melt-andpour origin should also become easier. This reasoning is appealing. It is also flawed. Consider a CBAM verifier conducting an on-site assessment at a non-EU producer of welded stainless-steel tubes. In the warehouse, a consignment of finished tubes destined for export to the European Union is ready for shipment. Yet the verifier’ s task is not to establish the emissions embedded in a specific lot of goods, but to assess overall emissions performance at installation level over the relevant period and determine an
average emissions intensity per tonne of output. That average is then allocated proportionally across production, including the consignment of tubes in front of him. From a CBAM perspective, the exercise is coherent and complete. Now imagine that this same verifier, with undiminished access to production records, input quantities, invoices, and internal documentation, were asked a different question: can you determine, with certainty, where the liquid steel contained in these tubes was melted? The verifier may identify the coldrolled coil from which the tubes were produced, as reflected in the installation’ s records. Beyond that point, however, the verifier can no longer rely on direct observation. Any indication of melt origin ultimately rests on certificates issued by previous operators, which cannot be physically corroborated on site. Even with full on-site access, the verifier cannot establish, with objective certainty, the country in which the liquid steel contained in those specific tubes was melted. The conclusion can extend no further than documentary consistency.
A fragmented documentary chain Now shift perspective. Imagine the same consignment of tubes presented to a customs officer at the EU border under a melt-and-pour origin rule. The legal question is no longer about emissions. It is about origin. The declared melt country may determine whether the shipment is subject to substantial duties or benefits from a favourable quota allocation.
It can be almost impossible to verify, with objective certainty, the country in which liquid steel originated. Photo: Dreamstime.
In Brussels, it is frequently suggested that the difficulty could be resolved by requiring importers to present the original mill test certificate issued by the steelmaker that performed the melt. At first glance, this appears decisive. In reality, that certificate refers to a primary product- typically a slab or billet- whose physical form and dimensions differ entirely from the finished tubes presented at importation. Between that initial melt and the final product lie successive stages of rolling, division, and transformation. A single heat can generate multiple slabs. Each slab can be rolled into coils. Each coil can be divided into numerous downstream products supplied to different customers and processed in different facilities. What connects these successive transformations is not a traceable physical continuity in the steel itself, but a fragmented documentary chain. Each operator issues a new certificate reflecting its own transformations, incorporating selected upstream
36 Stainless Steel World April 2026 www. stainless-steel-world. net