The EU’s Steel and Metals Action Plan (SMAP) has placed renewed emphasis on safeguarding the Union’s steel sector against the effects of global overcapacity and circumvention of existing trade policy measures. Central to this effort is the proposal of a ‘melted and poured rule’. A new draft regulation of 7 October 2025 includes a first proposal for a rule requiring the identification of the country of ‘melt and pour’ for steel products upon importation. On this occasion, this article examines issues of circumvention within the framework of EU trade defence law. It then analyses the new proposal’s first drafting, scope, and evidentiary requirements, and situates it in relation to established rules of origin under the Union Customs Code (UCC), as well as recent EU anti-circumvention investigations and sanctions practice. The article argues that the proposed rule functions as a traceability mechanism limited to one specific regulation and does not redefine non-preferential rules of origin. From this functional perspective, it could inform and inspire new anti-circumvention measures in the draft regulation and other trade instruments. The analysis also examines operational and compliance challenges it would pose for economic operators and customs authorities alike
Global Trade and Customs Journal