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 Šefčovič 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.

Crowell’s international trade attorneys are monitoring ongoing developments in the EU steel policy. For more information, please contact Vassilis Akritidis (vakritidis@crowell.com), Dan Cannistra (dcannistra@crowell.com) and Jean-Baptiste Blancardi (jblancardi@crowell.com).

Tags: European Union, Steel Tariffs
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Photo of Vassilis Akritidis Vassilis Akritidis

To maximize trade-related benefits, get customs advice, or ensure robust representation before the European Commission and EU courts in trade and EU matters, clients turn to Vassilis Akritidis and his team for clear advice and dedication to a positive result. Beyond disputes, proactive

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To maximize trade-related benefits, get customs advice, or ensure robust representation before the European Commission and EU courts in trade and EU matters, clients turn to Vassilis Akritidis and his team for clear advice and dedication to a positive result. Beyond disputes, proactive compliance and proper corporate governance are essential for success. Vassilis organizes compliance training programs for executives to ensure smooth and cost-effective navigation through the complex web of EU and World Trade Organization regulations.

Vassilis has been practicing EU and international trade law in Brussels since 1991. He qualified in Athens as a maritime lawyer and then pursued graduate studies in European law at the Institute of European Studies in Brussels. An internship at the State Aid Directorate-General for Competition convinced Vassilis that EU and supranational law are hugely interesting. He started as an EU competition and public procurement lawyer and over the years focused increasingly on international trade and WTO law. Vassilis is regularly quoted by renowned legal directories as an expert in these fields.

Vassilis helps his clients win trade investigations, achieve and improve market access, maximize trade benefits, and be trade-compliant wherever they operate. He advises and represents private clients, professional associations, and governments in trade defense investigations (anti-dumping, anti-subsidy, safeguards), customs investigations and litigation, trade sanctions/export controls, and EU anti-fraud investigations led by the European Anti-Fraud Office and the European Public Prosecutor’s Office. Vassilis also advises on EU State aid and EU internal market and public procurement.

Vassilis has worked for clients active in the steel, chemicals, high-tech, transport, defense and aerospace, automotive, and agriculture/food sectors. He represents clients before the EC and other non-EU trade defense authorities.

Should things get contentious, Vassilis is an experienced litigator, representing parties before EU courts in Luxembourg as well as national customs and administrative tribunals.

Vassilis works with his colleagues at Crowell Global Advisors, our global government relations, public policy, and public affairs affiliate, in matters involving EU public policy and lobbying.

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Photo of Daniel Cannistra Daniel Cannistra

Dan Cannistra is a partner in the firm’s Washington, D.C. office. His practice focuses on legislative, executive and regulatory representation of domestic and international clients on a broad spectrum of international trade matters. Dan has represented domestic and foreign companies in over 75

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Dan Cannistra is a partner in the firm’s Washington, D.C. office. His practice focuses on legislative, executive and regulatory representation of domestic and international clients on a broad spectrum of international trade matters. Dan has represented domestic and foreign companies in over 75 U.S. antidumping and countervailing duty cases before the U.S. Department of Commerce and the U.S. International Trade Commission under the Tariff Act of 1930. Many of these matters involved appeals to the U.S. Court of International Trade, the U.S. Court of Appeals for the Federal Circuit, binational panels under the North American Free Trade Agreement (NAFTA), and dispute settlement proceedings before the World Trade Organization (WTO). Dan has also represented clients in antidumping proceedings in the European Union, Canada, Mexico, Brazil, India, Thailand, Singapore, Guatemala and Taiwan.

Prior to joining Crowell & Moring, Dan was a director in a national accounting firm providing customs and international trade guidance to multinational clients related to the supply and distribution of goods and services across international borders. Areas of specialization included antidumping and countervailing duties and policy, trade remedies and litigation, free trade agreements and negotiations, classification and valuation, and international trade and development.

Dan’s government appointments include service to U.S. Trade Representative on the roster of international trade practitioners to resolve antidumping disputes involving NAFTA members. For the European Commission, Dan provided advice and training on international trade and antidumping methodology and practice. In addition, Dan has served as an international trade consultant to the governments of Guatemala and Singapore, providing technical advice to these governments on the application of international trade regulations consistent with international law and World Trade Organization agreements and the General Agreement on Tariffs and Trade, Agreement on Antidumping.

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Photo of Jean-Baptiste Blancardi Jean-Baptiste Blancardi

Jean-Baptiste Blancardi is an associate at Crowell & Moring, where he focuses on international trade law and on Environmental, Social, and Governance (ESG). His practice covers the broad spectrum of international trade law, including trade remedies investigations (antidumping, countervailing, and safeguard investigations) in…

Jean-Baptiste Blancardi is an associate at Crowell & Moring, where he focuses on international trade law and on Environmental, Social, and Governance (ESG). His practice covers the broad spectrum of international trade law, including trade remedies investigations (antidumping, countervailing, and safeguard investigations) in the EU and the U.S., as well as customs (origin, classification, duty refunds). In parallel, Jean-Baptiste advises clients on how to navigate the new EU regulations affecting trade in the Union and articulated around sustainability (Corporate Sustainability Due Diligence Directive, Carbon Border Adjustment Mechanism, Forced Labour Regulation) and open strategic autonomy (Foreign Subsidies Regulation, Anti-Coercion Instrument, Critical Raw Materials Act).

Prior to joining Crowell, Jean-Baptiste was a trainee at one of the most advanced ESG law firms in Paris, where he gained valuable experience relating to corporate sustainability reporting for groups with complex supply chains.

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