What documents does an EU buyer ask for in a ferroalloy quote, and which ones actually apply?

Last month an enquiry for silicon carbide came in from an EU buyer. The document list was long: COA, CBAM embedded-emissions data, EUR.1 and A.TR. Two of the four had nothing to attach to for that product, and one of the remaining two did the other's job. The same week a Ukrainian buyer asked for HC FeCr with an MTC to EN 10204 3.1. Short request, and correct. One quote settled in the first round, the other in the third email.

Purchasing teams tend to copy the document list from the previous supplier's file. Nobody wants a lot sitting at customs over a missing paper. But every line on that list is a cost item, a lead time, or a reply saying "not issued for this product".

Short answer: A COA comes with every lot. An MTC 3.1 under EN 10204 is the producer's document and ties lab results to the delivered lot. CBAM data matters for ferroalloys only on FeMn, FeCr and FeNi; FeSi, SiMn, FeMo and SiC are out of scope. A.TR is a movement certificate for goods in free circulation and does not prove origin. EUR.1 proves origin and is the document for ECSC (coal and steel) products between Türkiye and the EU. Asking for both on one shipment is usually a sign of a copied list.

COA and MTC 3.1 are not the same paper

A COA (certificate of analysis) gives the chemistry and sizing of the sample drawn from the lot. For HC FeCr that means Cr, C, Si, P and S; for SiC it means SiC, free C and Fe₂O₃. It travels with every lot.

An MTC 3.1 says something else. Under EN 10204, a type 3.1 inspection certificate is issued by the manufacturer, validated by its authorised inspection representative who is independent of the manufacturing department, and reports specific inspection results for the delivered lot. In other words, it is not something a trader can print on its own letterhead. If an intermediary sends you a "3.1" under its own signature, the best you are looking at is a 2.2. If you want independent third-party sign-off, the document you need is a 3.2: two signatories, and the inspection company's fee goes into the quote.

That is why the Ukrainian request was clean: product, grade, 3.1 per lot.

CBAM data: where it actually counts

Annex I of Regulation (EU) 2023/956 brings chapter 72 into scope, but with a long exception list for ferroalloys: FeSi (7202 2x), SiMn (7202 30 00), FeSiCr, FeMo, FeW, FeTi, FeV, FeNb, FeP and FeSiMg are out. What stays in is ferro-manganese, ferro-chromium and ferro-nickel. Silicon carbide sits under heading 2849 and does not appear in Annex I at all. Showing the buyer Annex I itself shortens the document list, and the quote no longer waits on data nobody will use.

FeCr and FeMn are a different story. The definitive period started on 1 January 2026, and the obligation sits with the importer in the EU. An importer whose CBAM goods stay at or below 50 tonnes net mass in a calendar year is exempt, and the threshold is counted across all CBAM goods together. Anyone going above it needs authorised CBAM declarant status; importers who applied by 31 March 2026 may keep importing until the authority decides. Certificate sales open on 1 February 2027, and the declaration and surrender for 2026 imports are due by 30 September 2027. The free-allocation adjustment is 97.5% for 2026 and 95% for 2027, so the first year is light on money and heavy on paperwork.

Embedded emissions are set one of two ways: actual data or default values. Actual data comes from the producing installation's monitoring and has to be verified by an accredited verifier. Default values are in Implementing Regulation (EU) 2025/2621, and for iron and steel they carry a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028. A trader does not generate this data; the plant does. Our job is to match it to the right lot and deliver it on time. The per-ton cost arithmetic is in our CBAM article.

A.TR and EUR.1: one is circulation, the other is origin

The Turkish Ministry of Trade puts it plainly: the A.TR movement certificate shows that goods are in free circulation and does not show their origin. EUR.1 proves origin. ECSC products fall outside the Türkiye-EU customs union, and for those EUR.1 or an invoice declaration is used instead of A.TR.

In practice, an industrial product in free circulation in Türkiye travels to the EU on an A.TR. Goods of third-country origin do not become Turkish because they were imported into Türkiye; the A.TR does not change their origin, it only records free circulation. That distinction bites on safeguards. The EU ferroalloy safeguard (Implementing Regulation (EU) 2025/2351) covers silicon, FeMn, FeSi, SiMn, FeSiMg and CaSi, and allocates its quotas by country of origin. FeCr and SiC are not in that measure.

EUR.1 requires preferential origin. If the goods do not have it, no EUR.1 is issued, and nobody should try. There is also the case where neither applies: goods not released into free circulation in Türkiye get no A.TR, and without preferential origin there is no EUR.1 either. The buyer then clears under the EU's general regime, by the goods' actual origin. Ask your broker before the quote whether your CN code is on the ECSC list; it depends on the subheading.

Back to the SiC enquiry: silicon carbide is a chemical, not a coal and steel product, so EUR.1 and A.TR together made no sense. We state origin and circulation status in the quote itself.

Radiation certificate and pre-shipment inspection

In ferroalloy enquiries from the EU, a radiation measurement certificate is close to a fixed line by now. It should show the lot's reading, the date of measurement and the body that took it. A generic "free of radioactivity" line will not satisfy a quality department.

Pre-shipment inspection by an independent company (SGS, Bureau Veritas and the like) covers sampling, weighing, analysis and loading supervision. It costs money, and the quote should say who pays. Otherwise the argument happens on loading day, the most expensive day to have it.

What to send with the RFQ

The information we need for a quote that comes back right first time is short:

• Product, grade and, if you have it, the 8-digit CN code
• Analysis limits and sizing (e.g. HC FeCr: Cr ≥60%, C ≤8.0%, 10-100 mm)
• Quantity, lot size, Incoterms and delivery point
• Documents per lot: COA, MTC type (2.2, 3.1 or 3.2), radiation
• If it is a CBAM good: will your annual CBAM imports exceed 50 t, and do you expect actual data
• Customs: A.TR, EUR.1, or neither (with your broker's answer)
• Inspection company, and which side pays

Mistakes we see on the desk

First, the copied list: CBAM data requested for FeSi or SiC and not for FeCr, because last year's file does not fit this year's product. Second, expecting a trader-signed 3.1. Third, treating A.TR as proof of origin and planning safeguard quota on that basis. Fourth, making "Turkish origin" a document condition. Origin is a fact about the goods and does not change on request. We do not write origin statements we cannot support, and we say so in the quote. Fifth, leaving the inspection cost open.

My call, with a date on it: the CBAM declaration for 2026 imports closes on 30 September 2027, and if it is going to rest on verified data, verification has to start months before that. An EU buyer of FeCr or FeMn should make actual emissions data a contract clause on every order placed in Q4 2026. A buyer still chasing data retroactively in January 2027 will most likely file the 2026 declaration on the 10% marked-up default and carry the same habit into 2027 at 20%.

Frequently Asked Questions

Do I need CBAM data for FeSi or SiC? No. Annex I of Regulation (EU) 2023/956 keeps FeSi (7202 2x) and SiMn on the exception list, and heading 2849, where SiC sits, is not in Annex I. FeMn, FeCr and FeNi are in scope.

Can a trader issue an MTC 3.1? No. Under EN 10204 the 3.1 is issued by the manufacturer and validated by an authorised inspection representative independent of production. If you want independent third-party validation, ask for a 3.2.

Does an A.TR show that goods are of Turkish origin? No. According to the Turkish Ministry of Trade, an A.TR shows free-circulation status, not origin. The origin document is EUR.1, which requires preferential origin.

On HC FeCr and SiC, a COA and the producer's MTC come with every lot as standard. For specs see the HC FeCr and SiC pages, and our certificates page for the document set. Fill in the list above and send it through the quote form, and the quote comes back with its documents in one go.

Sources: Regulation (EU) 2023/956, consolidated text of 20.10.2025, Articles 2a, 4, 5, 6, 7, 20, 22 and Annexes I, VII (EUR-Lex) · Implementing Regulation (EU) 2025/2621, default values (EUR-Lex) · Implementing Regulation (EU) 2025/2351, ferroalloy safeguard (EUR-Lex) · DEHSt, CBAM definitive regime (dehst.de) · European Commission CBAM page (taxation-customs.ec.europa.eu) · Turkish Ministry of Trade, origin FAQ (ticaret.gov.tr) · EN 10204 inspection document types (Giesserei-Lexikon).