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On October 7, 2025, the European Commission published a Proposal for a Regulation that imposes further trade restrictions on imports of steel products from non-EU countries. This Proposal is part of the implementation of the Commission's Steel and Metals Action Plan unveiled in March 2025, and aims to address the concerns of the EU steel manufacturing industry as the existing EU steel safeguards expire in June 2026.
This proposal marks a significant departure from the current EU trade policy and includes a stated intention to remain WTO-compliant. That would involve opening negotiations under Article XXVIII of the GATT to modify or withdraw certain WTO concessions for the steel products concerned and offer country-specific allocations to other WTO members. That is a challenging intention for an all-encompassing steel measure involving many WTO members having a substantial interest in EU exports. At the same time, it could be a first step in the creation of a "EU-US metals alliance" announced by EU Trade Commissioner `efčovič in July 2025.
Below are the key actions listed in the Proposal:
- New trade measure to replace the current steel safeguards.
This measure includes:
- Tariff Rate Quotas ("TRQs") for
global steel imports
- Set on an annual basis but managed quarterly,
- Specific to each product category (see Annex II of the Proposal),
- Set at a significantly lower level than the current steel safeguard TRQs (47% less),
- Product categories remain the same as in the steel safeguards with some limited differences to the customs codes listed in each product category (see Annex I of the Proposal listing the subject steel products)
- 50% tariffs on imports exceeding the TRQs without any exclusion procedure;
- TRQ levels based on 2013 market shares of steel imports;
- No carry-over from one quarter to another;
- No expiry date of the measure, allowing an indefinite enforcement;
- Assessment of the need to amend the measure within 2 years of its adoption;
- Evaluation of the measure's effectiveness by 1st July 2031 and every 5 years thereafter; and
- TRQs do not apply to imports of steel products from Norway, Iceland or Liechtenstein.
- Introduction of the "Melt and Pour" Rule.
The aim is to prevent circumvention of trade defence measures or tariffs in the steel sector. Origin of a steel product will now be determined by the original location in which raw steel and iron has been initially produced in liquid form within a steelmaking or iron-making furnace and subsequently cast into its primary solid state, regardless of further processing, be it arguably substantial. This is a total reversal of the EU origin rules in the steel sector, where substantial transformation, be it actual or based on "list rule" presumptions, was the rule.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
