What Every Member of the 

Trade Community Should Know About: 

Coated Nonalloy 

Flat-Rolled Steel 

AN INFORMED COMPLIANCE PUBLICATION 

MARCH 2010 
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 Word 2003®. 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®. 

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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 9th Street N.W. 7th 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

What is a flat-rolled product?........................................................................................ 7

What is clad, plated or coated? .................................................................................... 8

What is not clad, plated or coated? .............................................................................. 8

CLASSIFICATION GUIDELINES................................................................9

Industry specifications ................................................................................................ 10

Classification of clad, plated or coated flat-rolled nonalloy steel products.................. 10

Plated or coated with tin (Subheadings 7210.11, 7210.12 and 7212.10) ................... 11

*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

*Plated or coated with aluminum (Subheadings 7210.61, 7210.69 and *7212.50)..... 13

Painted, varnished or coated with plastics (Subheadings 7210.70 and 7212.40) ...... 14

Clad (Subheadings 7210.90.10 and 7212.60.00)....................................................... 15

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

The Internet................................................................................................................ 18

Customs Regulations ................................................................................................. 18

Customs Bulletin ........................................................................................................ 18

Importing into the United States ................................................................................. 19

Informed Compliance Publications............................................................................. 19

Value Publications...................................................................................................... 20

“Your Comments are Important”................................................................................. 21

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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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Coated Nonalloy Flat-Rolled Steel 

March 2010 

dimensional requirements specified in the above legal note. Although it is a flatrolled 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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Coated Nonalloy Flat-Rolled Steel 

March 2010 

-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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Coated Nonalloy Flat-Rolled Steel 

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, ColdRolled 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 corrosionresistance. 

-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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Coated Nonalloy Flat-Rolled Steel 

March 2010 

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. Flatrolled 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 zinccoated 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 ChromiumCoated, 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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Coated Nonalloy Flat-Rolled Steel 

March 2010 

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 flatrolled 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 

March 2010 

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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Coated Nonalloy Flat-Rolled Steel 

March 2010 

 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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