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Which EU rules apply to steel imported under fifty tonnes a year?

Steel imported below fifty tonnes a year: what the mass de minimis does and does not settle, and what still applies to you. This page is one fixed set of answers to the product check, written out in full. The wording comes from the same rule set the questionnaire uses, so the two cannot drift apart.

Triage, not a clearance. It sorts this situation into the right regimes; it does not classify your specific product, and classification is where most of the cost sits. Your own case may differ on any of the answers below; run the check with your own.

The answers this rests on

Open the check with these answers →

3 regimes apply to this situation

EPR; extended producer responsibilityif packaging comes with it

If any packaging accompanies these goods; including transport and industrial packaging, which most member states count; you are the producer of that packaging in every country where you first place it on the market. For genuinely unpackaged bulk, check before assuming it applies. There is no EU-wide register: each state has its own scheme, number, fee and report.

  • Packaging triggers it on its own; pallets, drums, wrapping and liners included in most states.
  • You named 1 member state; that many separate registrations, each with its own register, number and fee.
  • Register before the first sale into that country; several states treat selling without a number as an offence.
  • From 12 August 2026, if you make packaging or packaged products available for the first time in another member state directly to end users, you must appoint an authorised representative for extended producer responsibility there, by written mandate and per country. Sell to a distributor established in that country instead and he is the producer there, not you.
  • That first rule already covers you if you sit outside the EU and supply end users directly: Article 3(1), point (15)(c) and (d) says established in a member state or in a third country. Only if you sell to a distributor in that country instead is the mandate a member-state option rather than a duty.
National EPR regimes implementing Directive 2008/98/EC, Article 8a; Regulation (EU) 2025/40 (packaging), Article 45(3) read with Article 3(1), point (15)(c) and (d), and Article 71 (applies from 12 August 2026) · 2025/40 on EUR-Lex · read the full answer

CBAM; carbon border adjustmentout of scope under 50 t

Below 50 tonnes a year of iron and steel, aluminium, cement and fertilisers added together, you are out of CBAM for those goods; no reporting, no authorisation, no certificates. The Omnibus amendment replaced the old €150-per-shipment trigger with this mass-based de minimis. Two things to watch: hydrogen and electricity do not count towards the 50 tonnes and have no threshold of their own, so any quantity of those puts you in scope; and the total is annual and cumulative, with nobody warning you at 49 tonnes.

  • Embedded-emissions data for 2026 has to be collected during 2026, even though you pay later.
  • Certificates for 2026 imports can only be bought from February 2027.
  • The annual declaration for 2026 is due by 30 September 2027.
  • Get the data clause into your supplier contract now; suppliers who have never reported emissions are the usual bottleneck.
  • Electricity and hydrogen are on the list but are not weighed in tonnes; a mass de minimis does not settle those. Check that goods type on its own before relying on being out of scope.
Regulation (EU) 2023/956, as amended by Regulation (EU) 2025/2083; definitive regime since 1 January 2026 · 2023/956 on EUR-Lex · 2025/2083 on EUR-Lex · read the full answer

Sanctions screeningstill applies

It applies to every EU business regardless. Lists change with every round, so a party screened clean in January says nothing about a shipment in April.

  • Screen the name free on this site before you pay an invoice.
  • Ownership above 50% by a listed person catches a supplier that is not itself listed.
  • Your bank's screening is not your screening, and it is not a defence.
  • If you may have to show later that you checked, keep a dated record naming the list versions.
Regulation (EU) 269/2014 Article 2 and equivalents; Directive (EU) 2024/1226 · 269/2014 on EUR-Lex · read the full answer

This is the list of things to check, not a clearance. It leaves out CE, RoHS/WEEE, EUDR, food and cosmetics law and customs. Something wrong or missing? Corrections are made with the source noted.

What to do next, in this order

  1. Screen the name against nine sanctions lists before you pay, not after
  2. Pin down the goods code duty, CBAM scope and restrictions all hang off it
  3. Work out duty and VAT you bring the TARIC rate, the tool does the arithmetic
  4. Verify the VAT number on the day you invoice VIES, and keep the response

Where each of these is worked out

Does this not fit your case, or is something missing? Ask it here; questions are answered with the regulation and the article, and the questionnaire gets fixed. Providers who do this work are listed separately; being named there is not a recommendation.

Other situations, worked out the same way

What this does not cover

Named, because a triage tool that stays quiet about its edges is worse than none: