What Every Member of the
Trade Community Should Know About:
Coated Nonalloy
Flat-Rolled Steel
AN INFORMED COMPLIANCE PUBLICATION
MARCH 2010
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Coated Nonalloy Flat-Rolled Steel
March 2010
NOTICE:
This publication is intended to provide guidance and information to the trade community.
It reflects the position on or interpretation of the applicable laws or regulations by U.S.
Customs and Border Protection (CBP) as of the date of publication, which is shown on
the front cover. It does not in any way replace or supersede those laws or regulations.
Only the latest official version of the laws or regulations is authoritative.
Publication History
First Published: March 2000
Revised March 2004
Reviewed With No Changes May 2005
Reviewed With No Changes March 2006
Reviewed With No Changes January 2008
Revised March 2010
PRINTING NOTE:
This publication was designed for electronic distribution via the CBP website
(http://www.cbp.gov/) and is being distributed in a variety of formats. It was originally set
up in Microsoft Word97
®
. Pagination and margins in downloaded versions may vary
depending upon which word processor or printer you use. If you wish to maintain the
original settings, you may wish to download the .pdf version, which can then be printed
using the freely available Adobe Acrobat Reader
®
.
Coated Nonalloy Flat-Rolled Steel
March 2010
PREFACE
On December 8, 1993, Title VI of the North American Free Trade Agreement Implementation
Act (Pub. L. 103-182, 107 Stat. 2057), also known as the Customs Modernization or “Mod” Act,
became effective. These provisions amended many sections of the Tariff Act of 1930 and
related laws.
Two new concepts that emerge from the Mod Act are “informed compliance” and “shared
responsibility,” which are premised on the idea that in order to maximize voluntary compliance
with laws and regulations of U.S. Customs and Border Protection, the trade community needs to
be clearly and completely informed of its legal obligations. Accordingly, the Mod Act imposes a
greater obligation on CBP to provide the public with improved information concerning the trade
community's rights and responsibilities under customs regulations and related laws. In addition,
both the trade and U.S. Customs and Border Protection share responsibility for carrying out
these requirements. For example, under Section 484 of the Tariff Act, as amended (19 U.S.C.
1484), the importer of record is responsible for using reasonable care to enter, classify and
determine the value of imported merchandise and to provide any other information necessary to
enable U.S. Customs and Border Protection to properly assess duties, collect accurate
statistics, and determine whether other applicable legal requirements, if any, have been met.
CBP is then responsible for fixing the final classification and value of the merchandise. An
importer of record’s failure to exercise reasonable care could delay release of the merchandise
and, in some cases, could result in the imposition of penalties.
Regulations and Rulings (RR) of the Office of International Trade has been given a major role in
meeting the informed compliance responsibilities of U.S. Customs and Border Protection. In
order to provide information to the public, CBP has issued a series of informed compliance
publications on new or revised requirements, regulations or procedures, and a variety of
classification and valuation issues.
This publication, prepared by the National Commodity Specialist Division of Regulations and
Rulings is entitled "Coated Nonalloy Flat-Rolled Steel.” It provides guidance regarding the
classification of these items. We sincerely hope that this material, together with seminars and
increased access to rulings of U.S. Customs and Border Protection, will help the trade
community to improve voluntary compliance with customs laws and to understand the relevant
administrative processes.
The material in this publication is provided for general information purposes only. Because
many complicated factors can be involved in customs issues, an importer may wish to obtain a
ruling under Regulations of U.S. Customs and Border Protection, 19 C.F.R. Part 177, or to
obtain advice from an expert who specializes in customs matters, for example, a licensed
customs broker, attorney or consultant.
Comments and suggestions are welcomed and should be addressed to U.S. Customs and
Border Protection, Office of International Trade, Executive Director, Regulations and Rulings,
799 9
th
Street N.W. 7
th
floor, Washington, D.C. 20229-1177.
Sandra L. Bell
Executive Director, Regulations and Rulings
Office of International Trade
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INTRODUCTION..........................................................................................7
COATED NONALLOY FLAT-ROLLED STEEL..........................................7
........................................................................................7 What is a flat-rolled product?
....................................................................................8 What is clad, plated or coated?
..............................................................................8 What is not clad, plated or coated?
CLASSIFICATION GUIDELINES................................................................9
................................................................................................10 Industry specifications
..................10 Classification of clad, plated or coated flat-rolled nonalloy steel products
...................11 Plated or coated with tin (Subheadings 7210.11, 7210.12 and 7212.10)
*Plated or coated with lead, including terne-plate (Subheadings 7210.20 and
*7212.50.00)............................................................................................................... 11
Plated or coated with zinc (galvanized) (Subheadings 7210.30, 7210.41 7210.49,
7212.20 and 7212.30) ................................................................................................11
*Plated or coated with chromium oxides or with chromium and chromium oxides
(Subheadings 7210.50 and *7212.50)........................................................................ 13
..... 13 *Plated or coated with aluminum (Subheadings 7210.61, 7210.69 and *7212.50)
...... 14 Painted, varnished or coated with plastics (Subheadings 7210.70 and 7212.40)
.......................................................15 Clad (Subheadings 7210.90.10 and 7212.60.00)
Other (otherwise plated or coated) (Subheadings 7210.90.60, 7210.90.90 and
7212.50)..................................................................................................................... 15
INVOICING ................................................................................................16
ENTRY REQUIREMENTS.........................................................................16
ANTIDUMPING AND COUNTERVAILING DUTIES..................................16
REFERENCES...........................................................................................16
ADDITIONAL INFORMATION...................................................................18
................................................................................................................18 The Internet
.................................................................................................18 Customs Regulations
........................................................................................................18 Customs Bulletin
.................................................................................19 Importing into the United States
.............................................................................19 Informed Compliance Publications
......................................................................................................20 Value Publications
.................................................................................21 “Your Comments are Important”
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INTRODUCTION
COATED NONALLOY FLAT-ROLLED STEEL
Metallic and non-metallic coatings protect steel from corrosive elements found in the
environment. Certain coatings are decorative as well, improving the appearance of the
steel. There are numerous and varied applications for coated flat-rolled steel.
These include structural components, automotive parts, food and beverage containers,
household and cooking appliances, and various types of equipment and machinery.
Headings 7210 and 7212, Harmonized Tariff Schedule of the United States, (HTSUS),
provide for flat-rolled products of iron or nonalloy steel which are clad, plated or coated.
Most clad, plated or coated flat-rolled products will be classified under these two major
headings:
Heading 7210 covers flat-rolled products of iron or nonalloy steel, of a width of 600
mm or more, clad, plated or coated.
Heading 7212 covers flat-rolled products of iron or nonalloy steel, of a width of less
than 600 mm, clad, plated or coated.
In order to classify a product under one of the above headings, the product must be of
nonalloy steel, it must be flat-rolled as legally defined in the tariff (HTSUS) and it must
be clad, plated or coated.
What is a flat-rolled product?
Flat-rolled products are defined in HTSUS Chapter 72 Note 1. (k) as:
“Rolled products of solid rectangular (other than square) cross section... in the
form of:
- coils of successively superimposed layers (like tape or a roll of paper towels),
or
- straight lengths, which if of a thickness less than 4.75 mm are of a width
measuring at least 10 times the thickness or if of a thickness of 4.75 mm or
more are of a width which exceeds 150 mm and measures at least twice the
thickness.”
-Example: Flat-rolled steel strip in spirally oscillated coils, that is, wound back
and forth across a spool, is not in coils of successively superimposed layers
and therefore doesn’t meet the tariff definition for flat-rolled products.
-Example: A flat-rolled product of solid rectangular cross section in straight
lengths having a thickness of 4.75 mm and a width of 140 mm does not meet the
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dimensional requirements specified in the above legal note. Although it is a flat-
rolled product in straight lengths, it is not a flat-rolled product for tariff purposes.
What is clad, plated or coated?
The Explanatory Notes (EN’s) to heading 7210 state that the expression “clad, plated or
coated” applies to products which were subjected to one of the treatments described in
Part (C)(2), Items (d)(iv), (d)(v) and (e) of the General Explanatory Note to this Chapter:
(C) Subsequent manufacture and finishing
(2) Surface treatments
(d) Surface finishing treatment, including:
(iv) coating with metal (metallisation)...
(v) coating with non-metallic substances...
(e) Cladding
The products of these headings may be coated with metal, they may be coated with
non-metallic coatings, they may be clad or they may be coated with any combination of
metallic and non-metallic coatings.
-Metal (metallic) coatings: Some commonly used metallic coatings for steel are zinc,
tin, terne metal, lead, aluminum, aluminum-zinc alloy, chromium, nickel, cadmium,
copper, bronze, brass, silver and gold. Various processes are used to apply metallic
coatings to steel. The main processes used for applying metallic coatings to flat-rolled
steel products are the hot-dip process where the steel to be coated is immersed in a
bath of molten metal and the electrolytic process which, simply put, is applying a coating
of another metal on steel by means of an electric current and an electrolytic solution.
-Non-metallic coatings: Some commonly used non-metallic coatings are paint,
varnish, lacquer, plastic, enamel and ceramic.
-Cladding: Cladding is defined in Part (C)(2), item (e) of the General Explanatory Note to
Chapter 72 as “the association of layers of metals of different colours or natures by molecular
interpenetration of the surfaces in contact.” Various methods of cladding are described in this
EN. They include pouring molten cladding metal on the base metal, followed by rolling; simple
hot-rolling of the cladding metal to the basic metal to ensure efficient welding; any other method
of deposition or superimposition of the cladding metal followed by any mechanical or thermal
process to ensure welding. (Note: base metal clad with precious metal is classified in Chapter
71)
What is not clad, plated or coated?
Certain surface treatments are not considered to be cladding, plating or coating.
-Example: Flat-rolled products merely treated with rust preventative coatings
such as oil, wax, silicates and acrylic-based dry film lubricants are not “clad,
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Coated Nonalloy Flat-Rolled Steel
March 2010
plated or coated” for purposes of classification under headings 7210 and 7212.
Certain surface finishing treatments including chemical surface treatments are not
considered to be cladding, plating or coating.
-Example: Flat-rolled products subjected to chromating or phosphate treatments
or to blueing, bronzing or browning are not “clad, plated or coated” for purposes
of classification under headings 7210 and 7212.
See Part (lV)(C)(2), Items (c) and (d)(ii) & (iii) of the General Explanatory Notes to
Chapter 72.
CLASSIFICATION GUIDELINES
-Last process: For the purpose of headings 7210 and 7212, products subjected to
more than one type of coating, plating or cladding are to be classified according to the
last process. However, chemical surface treatments (such as chromating) are not
regarded as the last process. See the Subheading Explanatory Notes to heading 7210.
-Example: Steel plated with zinc (galvanized) and then painted will be classified
under the HTSUS subheading “painted, varnished or coated with plastics”.
-Example: Steel plated with zinc (galvanized) and chromate treated will be
classified under the HTSUS subheading “plated or coated with zinc”.
-Combination coatings: Flat-rolled products coated or plated with a combination
coating such as aluminum-zinc alloy or zinc-nickel alloy are always classified based on
which metal in the coating predominates by weight. This is in accordance with HTSUS
Section XV Notes 5. (a), 5. (c) and 6.
Note 5. (a) states: “An alloy of base metals is to be classified as an alloy of the metal
which predominates by weight over each of the other metals.”
Example
-
: An alloy of base metals such as aluminum-zinc alloy is to be
classified as an alloy of the metal which predominates by weight over each of
the other metals, e.g., aluminum 55%, zinc 44%.
Note 5. (c) states: “In this section the term “
alloys” includes... heterogeneous intimate
mixtures obtained by melting....”
Note 6. states: “Unless the context otherwise requires, any reference in the tariff
schedule to a base metal includes a reference to alloys which, by virtue of note 5 above,
are to be classified as alloys of that metal.”
-Example: “Coated with aluminum” would include products coated with an
aluminum-zinc alloy coating, e.g. aluminum 55%, zinc 44%.
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-Clad products: HTSUS Chapter 72 Note 2 states “Ferrous metals clad with another
ferrous metal are to be classified as products of the ferrous metal predominating by
weight.”
-Example: Flat-rolled nonalloy steel clad with stainless steel in which the
nonalloy steel predominates by weight will be classified in Subchapter II of
Chapter 72, IRON AND NONALLOY STEEL under the appropriate subheadings
of headings 7210 or 7212, rather than under a subheading for flat-rolled
products of stainless steel in Subchapter III of Chapter 72, STAINLESS STEEL.
In classifying ferrous metals clad with non-ferrous metals, HTSUS Section XV Note 7
states that articles of base metals (e.g., iron, steel, copper, nickel, aluminum, lead, zinc,
tin, etc.) containing two or more base metals will be classified as products of the base
metal which predominates by weight.
-Example: Flat-rolled nonalloy steel clad with aluminum in which the nonalloy
steel predominates by weight will be classified in Chapter 72, IRON AND STEEL,
under headings 7210 or 7212 rather than in Chapter 76, ALUMINUM AND
ARTICLES THEREOF.
Industry specifications
The American Society for Testing and Materials (ASTM) publishes standard
specifications for a multitude of different products. Annual Book of ASTM Standards,
Section I, Iron and Steel Products, Volume 01.06, Coated Steel Products, contains
standard specifications for products which are the subject of this report. Knowing the
applicable ASTM specification for a particular product aids in determining the proper
classification of such product.
Classification of clad, plated or coated flat-rolled nonalloy steel
products
Heading 7210: All subheadings under heading 7210 cover flat-rolled products of iron or
nonalloy steel, of a width of 600 mm or more.
Heading 7212: All subheadings under heading 7212 cover flat-rolled products of iron or
nonalloy steel, of a width of less than 600 mm.
*Note: Certain metal coatings are specifically provided for in the subheadings of
heading 7210, but not under the subheadings of heading 7212: lead and terne
metal, chromium oxides or chromium and chromium oxides and aluminum,
including aluminum-zinc. Flat-rolled products of heading 7212 coated or plated
with such metals will be classified under subheading 7212.50.00 which provides
for “Otherwise coated or plated”. An asterisk * will appear when this occurs.
Remember: When classifying a product under any of the following subheadings,
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March 2010
refer to the Classification Guidelines to see whether any of these guidelines are
applicable.
Plated or coated with tin (Subheadings 7210.11, 7210.12 and 7212.10)
These flat-rolled products are plated or coated with tin usually by electrolytic deposition.
Some uses for this material include food and beverage containers and electronic
equipment. Flat-rolled products of nonalloy steel made to the following ASTM
specifications would be classified under these subheadings unless the Classification
Guidelines indicate otherwise.
A 624, Standard Specification for Tin Mill Products, Electrolytic Tin Plate, Single
Reduced
A 626, Standard Specification for Tin Mill Products, Electrolytic Tin Plate, Double
Reduced
A 599, Standard Specification for Tin Mill Products, Electrolytic Tin-Coated, Cold-
Rolled Sheet
*Plated or coated with lead, including terne-plate (Subheadings
7210.20 and *7212.50.00)
Terne metal is an alloy of lead and tin. The lead/tin combination varies, for example,
lead with 3%-15% by weight of tin. There are also nickel-terne combination coatings
(NI-TERNE). The nickel coating is under the lead-tin coating for extra corrosion-
resistance.
-Example: Steel sheet coated with nickel-terne alloy (NI-TERNE) combination
coatings would be classified here because products subjected to more than one
type of coating, plating or cladding are classified according to the last process.
The last process is the terne (lead-tin) coating.
Some of the uses for this type of coated material include roofing, gutters, down spouts,
oil filter shells, radiator parts, oil cans, paint containers, file drawer tracks, fire doors and
frames, automotive fuel tanks and small fuel tanks for lawn mowers, tractors and
outboard motors. Flat-rolled products of nonalloy steel made to the following ASTM
specification would be classified under these subheadings unless the Classification
Guidelines indicate otherwise:
A 308, Standard Specification for Steel Sheet, Terne (Lead-Tin Alloy) Coated by the
Hot-Dip Process
Plated or coated with zinc (galvanized) (Subheadings 7210.30, 7210.41
7210.49, 7212.20 and 7212.30)
In addition to barrier protection, zinc and zinc-alloys offer sacrificial protection. If a
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steel sheet coated with zinc is scratched or nicked on the surface, the zinc sacrifices
itself to protect the steel. This is also called galvanic action. Some metals, such as
zinc, are more electrochemically active than other metals, such as steel. These more
active metals provide sacrificial protection to less active metals.
Electrolytically plated or coated with zinc (galvanized) (Subheadings 7210.30 and
7212.20)
These products are coated with zinc or with zinc-nickel alloy (9-16% nickel/balance
zinc) by means of electrolytic deposition--applying a coating of another metal on steel
by means of an electric current and electrolytic solution. Some uses for such coated
material include automotive body parts, appliances and architectural applications. Flat-
rolled products of nonalloy steel made to the following ASTM specifications would be
classified under these subheadings unless the Classification Guidelines indicate
otherwise:
A 591, Standard Specification for Steel Sheet, Electrolytic Zinc-Coated, for Light
Coating Weight (Mass) Applications
A 879, Standard Specification for Steel Sheet, Zinc Coated by the Electrolytic
Process for Applications Requiring Designation of the Coating Mass on Each
Surface
A 918, Standard Specification for Steel Sheet, Zinc-Nickel Alloy Coated by the
Electrolytic Process for Applications Requiring Designation of the Coating
Mass on Each Surface
As is illustrated here, if the applicable specification is known, it becomes easier to
properly classify the product. The above specifications are for electrolytically zinc-
coated products, and subheadings 7210.30 and 7212.20 cover products
electrolytically plated or coated with zinc.
Otherwise plated or coated with zinc (hot-dip galvanized and Galvannealed)
(Subheadings 7210.41, 7210.49 and 7212.30)
The vast majority of products covered by these subheadings are those that have been
hot-dip galvanized, that is, immersed in a bath of molten zinc. Most zinc-coated steel is
processed by hot-dip galvanizing. The hot-dip galvanizing process results in a zinc
coating having a crystal structure or “spangled” finish. This galvanized coating provides
excellent sacrificial protection. Some uses for such coated material include air
conditioning equipment, automotive parts—body panels and structural members,
building panels, ductwork and garbage cans. Galvannealed products are classified
under these subheadings. Galvannealed products are coated with zinc on both sides
and are heat treated after the zinc coating is applied. The heat treatment converts the
coating to a zinc-iron alloy (10-12% iron/balance zinc). This coating is harder and more
scratch-resistant than regular galvanized and corrodes more slowly than pure zinc
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Coated Nonalloy Flat-Rolled Steel
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coating. Some uses for such coated material include automotive parts--both exposed
and unexposed applications, buses and trucks, garage doors, highway signs and
vending machines. Flat-rolled products of nonalloy steel made to the following ASTM
specification would be classified under these subheadings unless the Classification
Guidelines indicate otherwise:
A 653, Standard Specification for Steel Sheet, Zinc-Coated (Galvanized) or Zinc-Iron
Alloy-Coated (Galvannealed) by the Hot-Dip Process
Chromate and phosphate treatments may be used on zinc-coated surfaces to provide
extra corrosion resistance or for providing a good adherent base for later paint
treatments. Phosphate coatings or other chemical surface treatments are NOT
considered the “last coating, plating, cladding process” for classification purposes.
Therefore, a galvanized flat-rolled product that has been phosphatized or chromate
treated will be classified under the subheading “plated or coated with zinc”.
Subheading 7210.41 covers corrugated flat-rolled products otherwise plated or coated
with zinc. The Chapter 72 Explanatory Notes state that “corrugated flat-rolled products”
means those products having a regular wave pattern in the form of a curved (e.g.,
sinusoidal) line. “Ribbed” products having an angular profile (e.g., square, triangular or
trapezoidal) are not considered corrugated flat-rolled products.
*Plated or coated with chromium oxides or with chromium and
chromium oxides (Subheadings 7210.50 and *7212.50)
Electrolytic chromium-coated steel is also referred to as tin-free steel (“TFS”). This is
black plate (very thin cold-rolled steel) electrolytically plated with metallic chromium plus
a chromium-oxide film. Some of the uses for such coated products include beer and
soda three-piece cans and ends, ends for food cans and caps and crowns for glass
containers. Flat-rolled products of nonalloy steel made to the following ASTM
specification would be classified under these subheadings unless the Classification
Guidelines indicate otherwise:
A 657, Standard Specification for Tin Mill Products, Black Plate, Electrolytic Chromium-
Coated, Single and Double Reduced (Note: Black Plate is uncoated cold rolled
sheet used as a precursor for tinplate. It is classified in subheading 7209.18.25)
*Plated or coated with aluminum (Subheadings 7210.61, 7210.69 and
*7212.50)
The products classified under these subheadings include those plated or coated with
pure aluminum, products coated or plated with “combination” or alloy coatings such as
aluminum-zinc alloy coatings and aluminum-silicon alloy coatings where aluminum
predominates by weight over each of the other metals.
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Plated or coated with aluminum-zinc alloys (Subheadings 7210.61 and *7212.50)
These products are coated with aluminum-zinc alloys in which aluminum
predominates by weight in this “combination” coating.
-Example: GALVALUME sheet, coated by the hot-dip process and containing, by
weight, approximately 55% aluminum, 1.6% silicon and the balance zinc, would
be classified under these subheadings.
Some uses for such coated products include building panels, industrial roofing and
siding, automotive under-body parts and mufflers, freezers, home laundry appliances,
playground equipment and outdoor furniture. Flat-rolled products of nonalloy steel
made to the following ASTM specification would be classified under these subheadings
unless the Classification Guidelines indicate otherwise:
A 792, Standard Specification for Steel Sheet, 55 % Aluminum-Zinc Alloy-Coated by the
Hot-Dip Process
Other (plated or coated with aluminum) (Subheadings 7210.69 and *7212.50)
Products covered by these subheadings include other aluminum plated or coated flat-
rolled products.
-Example: Steel sheet hot-dip coated with pure aluminum or hot-dip coated with
aluminum-silicon alloy combination coatings (5-11% silicon/balance aluminum)
would be classified under these subheadings.
Some uses for such coated products include baking pans, furnaces, space heaters and
incinerators. Flat-rolled products of nonalloy steel made to the following ASTM
specification would be classified under these subheadings unless the Classification
Guidelines indicate otherwise:
A 463, Standard Specification for Steel Sheet, Aluminum-Coated, by the Hot-Dip
Process
Painted, varnished or coated with plastics (Subheadings 7210.70 and
7212.40)
The products classified under these subheadings include those that have been coated
with paint, varnish, lacquer or plastics. Some examples of these coatings are plastisols,
polyesters, epoxies, acrylics and polyvinyl chloride (PVC). These subheadings would
also include products coated with zinc-rich primers such as Zincrometal. Headquarters
ruling 081803, dated August 15, 1990, addresses the issue of whether Zincrometal
coated products are classifiable as products coated or plated with metal (zinc) or as
products painted or varnished. Zincrometal is described in this ruling as a two-coat
system consisting of a base coat and a top coat. The base coat is a water-based
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Coated Nonalloy Flat-Rolled Steel
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dispersion containing chromic acid and the top coat is composed of zinc dust
encapsulated in an epoxy resin binder. These coatings are applied to the steel and
baked. Headquarters ruled that since Zincrometal is considered an organic paint
coating and there is no metal to metal bond with the coating and the substrate,
Zincrometal coated products are classifiable as painted products.
Since products subjected to more than one type of coating plating or cladding are to be
classified according to the last process, these subheadings include products that have
been metal coated or plated or clad and then painted, varnished or coated with plastics.
Subheading 7210.70.60 covers products that are first coated or plated with metal or
clad and then painted, varnished or coated with plastics. Subheading 7210.70.30
covers products that are painted, varnished or coated with plastics but not coated or
plated with metal and not clad. Subheading 7212. 40 covers both products that are
first coated or plated with metal or clad and then painted, varnished and coated with
plastics and products that are painted, varnished or coated with plastics but not coated
or plated with metal and not clad.
Clad (Subheadings 7210.90.10 and 7212.60.00)
Clad metals are composite metals. Cladding, as previously described, is the
association of layers of metal of different natures by molecular interpenetration of the
surfaces in contact. Types of clad materials include stainless steel on carbon or
nonalloy steel, stainless steel on copper, copper on steel, aluminum on steel and nickel
on steel. HTSUS Section XV, Note 7 and Chapter 72, Note 2 govern the classification
of clad products. Refer to Classification Guidelines, Clad products for examples of
classifying clad products.
Other (otherwise plated or coated) (Subheadings 7210.90.60,
7210.90.90 and 7212.50)
These subheadings cover all other plated or coated products not covered by the
previous subheadings. This includes any products of heading 7210 coated with metal
other than tin, lead, terne-plate, zinc, chromium and chromium oxides, aluminum or with
non-metallic coatings other than paint, varnish or plastics or clad. Thus, such products
that are electrolytically coated or plated with base metals not specifically provided for
are classified under subheading 7210.90.60. All other products having metallic or
nonmetallic coatings not specifically provided for are classified under subheading
7210.90.90.
-Example: Aluminum plated (NOT electrolytically plated) sheet measuring over
600 mm in width with a porcelain enamel coating baked on the aluminum layer
will be classified under subheading 7210.90.90. Products subjected to more than
one type of coating, plating or cladding are classified according to the last
process. The last process is the enamel coating, a nonmetallic coating other
than paint, varnish or plastic.
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Coated Nonalloy Flat-Rolled Steel
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Any products of heading 7212 coated with metal other than tin or zinc or with
nonmetallic coatings other than paint, varnish or plastics or clad are classified under
subheading 7212.50.
Example
-
: See examples provided throughout this report that are indicated by an
asterisk (*).
INVOICING
It is important to provide a detailed description of the imported product to ensure proper
classification. For coated nonalloy flat-rolled steel, the description should include the
grade of steel (chemical composition) and the dimensions of the product (including
whether it is in coils or cut-to-length). If the product is in coil form, specify whether it is in
coils of successively superimposed layers or spirally oscillated. The type of coating or
coatings (if there is more than one coating) should be clearly indicated, along with the
sequence in which the coatings are applied. For combination or alloy coatings, include
the percent, by weight, of each of the metals in the coating. The method of
coating/plating (e.g., electrolytic coating, hot-dip coating, etc.) should be provided. Any
applicable specifications such as ASTM specifications should also be supplied.
ENTRY REQUIREMENTS
Section 141.89 (a) of the U.S. Customs and Border Protection (CBP) Regulations
outlines the additional information that is required at time of entry for certain classes of
merchandise. For the products of Chapter 72 and headings 7301 to 7307, HTSUS, this
requirement is a statement of the percentages of weight of carbon and any metallic
elements contained in the articles in the form of a mill analysis or mill test certificate. A
mill test certificate is required for each entry of coated nonalloy flat-rolled steel products
of Chapter 72.
ANTIDUMPING AND COUNTERVAILING DUTIES
There are various antidumping and countervailing duty (AD/CVD) cases that presently
cover Coated Nonalloy Flat-rolled Steel. A list of current antidumping and
countervailing duty cases can be found at the International Trade Commission website
at www.usitc.gov. A list of AD/CVD orders currently in effect is maintained by the
Department of Commerce and can be found on the Import Administration section of the
International Trade Administration website at
www.trade.gov/ia/. In addition, AD/CVD
deposit and liquidation messages are available using the AD/CVD search tool at the
CBP website at
http://addcvd.cbp.gov/. Furthermore, information can be obtained by
contacting the office of Field Operations at your local port of entry.
REFERENCES
Information from the following publications was used in the preparation of this Informed
Compliance Publication.
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American Galvanizers Association. Zinc Coatings. Aurora, Colorado: 1993.
American Iron and Steel Institute, Automotive Applications Committee. Cracking
Down on Corrosion. Southfield, Michigan.
American Society for Testing and Materials, 1998 Annual Book of ASTM Standards,
Volume 01.06. Coated Steel Products. West Conshohocken, PA: ASTM, 1998.
Carson, Robert W. “Cladding.” McGraw-Hill Multimedia Encyclopedia of Science &
Technology. CD-ROM. 1995
Explanatory Notes to the Harmonized Commodity Description and Coding System.
Brussels: Customs Cooperation Council, 1996.
Farrell, R. F. “Metal Coatings.” McGraw-Hill Multimedia Encyclopedia of Science &
Technology. CD-ROM. 1995.
Harmonized Tariff Schedule of the United States, 1999. Washington DC: United
States International Trade Commission, 1999.
Lankford, William T., Jr., Norman L. Samways, Robert F. Craven and Harold E.
McGannon, eds. The Making, Shaping and Treating of Steel. Pittsburgh: United
States Steel Corporation, 1985
Leonard, R. W. “Precoated Steel Sheet.” Metals Handbook, Volume 1, ASM
International, Materials Park, OH, 1990, p. 212-225.
United States Steel Corporation. USS Coated Steel Sheet. Pittsburgh: 1990.
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ADDITIONAL INFORMATION
The Internet
The home page of U.S. Customs and Border Protection on the Internet’s World Wide
Web, provides the trade community with current, relevant information regarding CBP
operations and items of special interest. The site posts information -- which includes
proposed regulations, news releases, publications and notices, etc. -- that can be
searched, read on-line, printed or downloaded to your personal computer. The web site
was established as a trade-friendly mechanism to assist the importing and exporting
community. The web site also links to the home pages of many other agencies whose
importing or exporting regulations that U.S. Customs and Border Protection helps to
enforce. The web site also contains a wealth of information of interest to a broader
public than the trade community. For instance, the “Know Before You Go” publication
and traveler awareness campaign is designed to help educate international travelers.
The web address of U.S. Customs and Border Protection is http://www.cbp.gov
Customs Regulations
The current edition of Customs and Border Protection Regulations of the United States
is a loose-leaf, subscription publication available from the Superintendent of
Documents, U.S. Government Printing Office, Washington, DC 20402; telephone (202)
512-1800. A bound edition of Title 19, Code of Federal Regulations is also available for
sale from the same address. All proposed and final regulations are published in the
Federal Register, which is published daily by the Office of the Federal Register, National
Archives and Records Administration, and distributed by the Superintendent of
Documents. Information about on-line access to the Federal Register may be obtained
by calling (202) 512-1530 between 7 a.m. and 5 p.m. Eastern time. These notices are
also published in the weekly Customs Bulletin described below.
Customs Bulletin
The Customs Bulletin and Decisions (“Customs Bulletin”) is a weekly publication that
contains decisions, rulings, regulatory proposals, notices and other information of
interest to the trade community. It also contains decisions issued by the U.S. Court of
International Trade, as well as customs-related decisions of the U.S. Court of Appeals
for the Federal Circuit. Each year, the Government Printing Office publishes bound
volumes of the Customs Bulletin. Subscriptions may be purchased from the
Superintendent of Documents at the address and phone number listed above.
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Importing into the United States
This publication provides an overview of the importing process and contains general
information about import requirements. The current edition of Importing Into the United
States contains much new and revised material brought about pursuant to the Customs
Modernization Act (“Mod Act”). The Mod Act has fundamentally altered the relationship
between importers and U.S. Customs and Border Protection by shifting to the importer
the legal responsibility for declaring the value, classification, and rate of duty applicable
to entered merchandise.
The current edition contains a section entitled "Informed Compliance." A key component
of informed compliance is the shared responsibility between U.S. Customs and Border
Protection and the import community, wherein CBP communicates its requirements to
the importer, and the importer, in turn, uses reasonable care to assure that CBP is
provided accurate and timely data pertaining to his or her importation.
Single copies may be obtained from local offices of U.S. Customs and Border
Protection, or from the Office of Public Affairs, U.S. Customs and Border Protection,
1300 Pennsylvania Avenue NW, Washington, DC 20229. An on-line version is
available at the CBP web site. Importing into the United States is also available for
sale, in single copies or bulk orders, from the Superintendent of Documents by calling
(202) 512-1800, or by mail from the Superintendent of Documents, Government Printing
Office, P.O. Box 371954, Pittsburgh, PA 15250-7054.
Informed Compliance Publications
U.S. Customs and Border Protection has prepared a number of Informed Compliance
publications in the “What Every Member of the Trade Community Should Know
About:…” series. Check the Internet web site http://www.cbp.gov for current
publications.
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Value Publications
Customs Valuation under the Trade Agreements Act of 1979 is a 96-page book
containing a detailed narrative description of the customs valuation system, the customs
valuation title of the Trade Agreements Act (§402 of the Tariff Act of 1930, as amended
by the Trade Agreements Act of 1979 (19 U.S.C. §1401a)), the Statement of
Administrative Action which was sent to the U.S. Congress in conjunction with the TAA,
regulations (19 C.F.R. §§152.000-152.108) implementing the valuation system (a few
sections of the regulations have been amended subsequent to the publication of the
book) and questions and answers concerning the valuation system.
Customs Valuation Encyclopedia (with updates) is comprised of relevant statutory
provisions, CBP Regulations implementing the statute, portions of the Customs
Valuation Code, judicial precedent, and administrative rulings involving application of
valuation law. A copy may be purchased for a nominal charge from the Superintendent
of Documents, Government Printing Office, P.O. Box 371954, Pittsburgh, PA 15250-
7054. This publication is also available on the Internet web site of U.S. Customs and
Border Protection.
The information provided in this publication is for general information
purposes only. Recognizing that many complicated factors may be
involved in customs issues, an importer may wish to obtain a ruling under
CBP Regulations, 19 C.F.R. Part 177, or obtain advice from an expert
(such as a licensed Customs Broker, attorney or consultant) who
specializes in customs matters. Reliance solely on the general
information in this pamphlet may not be considered reasonable care.
Additional information may also be obtained from U.S. Customs and Border Protection
ports of entry. Please consult your telephone directory for an office near you. The
listing will be found under U.S. Government, Department of Homeland Security.
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“Your Comments are Important”
The Small Business and Regulatory Enforcement Ombudsman and 10 regional
Fairness Boards were established to receive comments from small businesses about
Federal agency enforcement activities and rate each agency’s responsiveness to small
business. If you wish to comment on the enforcement actions of U.S. Customs and
Border Protection, call 1-888-REG-FAIR (1-888-734-3247).
REPORT SMUGGLING 1-800-BE-ALERT OR 1-800-NO-DROGA
Visit our Internet web site: http://www.cbp.gov
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