HTS Classification for Steel, Metals, and Alloys: Chapters 72-83 Guide for U.S. Importers

Metals Classification in the Era of Section 232

The classification of metals and alloys has always been technically demanding, requiring knowledge of metallurgy, alloy compositions, and manufacturing processes. But since 2018, it has also become one of the most financially consequential areas of tariff classification due to Section 232 national security tariffs. A 25% tariff on steel and a 10% tariff on aluminum apply to a wide range of metal products imported into the United States, but the scope of these tariffs is defined by HTS classification. Whether your product is subject to Section 232 duties depends entirely on whether it classifies under the HTS headings covered by the presidential proclamations. This creates a situation where seemingly minor classification distinctions — the difference between a 'steel article' and an 'article of steel' — can mean a 25% duty rate swing. Chapters 72 through 83 of the HTS cover the full range of base metals and articles thereof, and this guide will walk through the key classification principles.

Chapter 72: Iron and Steel

Chapter 72 covers iron and steel in semi-manufactured and basic forms. The chapter is organized by product form and by steel type. Headings 7201-7205 cover primary materials: pig iron (7201), ferroalloys (7202), ferrous products from direct reduction (7203), ferrous waste and scrap (7204), and granules and powders (7205). Headings 7206-7207 cover iron and non-alloy steel in ingots and semi-finished forms. Headings 7208-7212 cover flat-rolled products of iron or non-alloy steel — this is where most commercial steel sheet, plate, coil, and strip is classified, with subheadings based on whether the product is hot-rolled (7208), cold-rolled (7209), clad, plated, or coated (7210), or in narrower widths (7211-7212). Headings 7213-7217 cover bars, rods, angles, shapes, sections, and wire of iron or non-alloy steel. Headings 7218-7223 cover stainless steel in the same progression of forms. Headings 7224-7229 cover other alloy steel. The classification within Chapter 72 depends on steel type (non-alloy, stainless, other alloy), product form (flat-rolled, bars, wire, etc.), dimensions, surface treatment, and whether the product is hot-rolled or cold-rolled.

Understanding Steel Grades and Alloy Classification

The HTS distinguishes between three main categories of steel, and the classification depends on the alloy composition. Non-alloy steel (also called carbon steel) is iron with carbon content up to about 2% and minimal other alloying elements. Stainless steel is defined in Note 1(d) to Chapter 72 as alloy steel containing by weight 1.2% or less of carbon and 10.5% or more of chromium, with or without other elements. Other alloy steel includes any steel that does not qualify as stainless but contains one or more alloying elements exceeding specified thresholds — for example, more than 0.3% chromium (below the stainless threshold), more than 0.08% molybdenum, more than 0.1% nickel, or more than 0.6% manganese. The alloy composition must be verified against the specific thresholds in Note 1 to Chapter 72 to determine the correct category. Mill test certificates (MTCs) or certificates of analysis are essential documentation for metal classification.

• Hot-rolled steel sheet/coil (non-alloy): 7208
• Cold-rolled steel sheet/coil (non-alloy): 7209
• Galvanized steel sheet: 7210.49
• Stainless steel flat-rolled (hot): 7219
• Stainless steel flat-rolled (cold): 7220
• Steel bars and rods (hot-rolled, non-alloy): 7213-7214
• Steel wire: 7217 (non-alloy), 7223 (stainless)
• Steel pipe and tubes: 7304-7306
• Steel structures and parts: 7308
• Aluminum unwrought: 7601
• Aluminum plates, sheets, strip: 7606-7607
• Aluminum structures and parts: 7610
• Copper cathodes: 7403
• Copper wire: 7408
• Copper tubes and pipes: 7411

Aluminum: Chapter 76

Chapter 76 covers aluminum and articles thereof. Heading 7601 covers unwrought aluminum — both unalloyed and alloyed. The distinction between alloyed and unalloyed aluminum is defined in Note 1 to Chapter 76: unalloyed aluminum contains by weight at least 99% aluminum. Heading 7602 covers aluminum waste and scrap. Heading 7604 covers bars, rods, and profiles. Heading 7605 covers wire. Headings 7606-7607 cover plates, sheets, strip, and foil. Heading 7608 covers tubes and pipes. Heading 7609 covers tube and pipe fittings. Heading 7610 covers aluminum structures and parts of structures, including doors, windows, and frames. Headings 7611-7616 cover various articles of aluminum, from reservoirs and casks to household articles. Section 232 tariffs apply to many of these headings at a 10% rate, though certain country-specific exemptions and product exclusions may apply. The exclusion process for Section 232 aluminum tariffs mirrors the steel process, requiring importers to apply for specific product exclusions.

Copper, Precious Metals, and Other Base Metals

Chapter 74 covers copper and articles thereof, with similar organization to the steel and aluminum chapters — from refined copper (7403) through semi-manufactured forms (plates, sheets, bars, wire, tubes) to finished articles. Copper alloys like brass (copper-zinc) and bronze (copper-tin) are classified within Chapter 74 based on their copper content and alloy composition. Chapter 75 covers nickel. Chapter 78 covers lead. Chapter 79 covers zinc. Chapter 80 covers tin. Chapter 81 covers other base metals including tungsten, molybdenum, tantalum, and titanium — these specialty metals are increasingly important in aerospace, defense, and technology applications. Precious metals — silver, gold, and platinum group metals — are classified under Chapter 71, which also covers jewelry, pearls, and precious stones. The classification of precious metals depends on whether they are in unwrought form, semi-manufactured form (bars, wire, sheet), or finished articles (jewelry, coins).

Chapter 73: Articles of Iron or Steel

Chapter 73 is where finished steel articles are classified — as opposed to Chapter 72, which covers steel in basic and semi-manufactured forms. Key headings include 7304-7306 (tubes, pipes, and hollow profiles), 7307 (tube and pipe fittings), 7308 (structures and parts of structures — bridges, towers, columns, frameworks), 7309 (reservoirs, tanks, vats), 7310 (tanks, casks, drums for transport), 7311 (compressed gas containers), 7312 (stranded wire, ropes, cables), 7313 (barbed wire), 7314 (cloth, grill, netting), 7315 (chain), 7316-7317 (anchors, nails, screws), 7318 (bolts, nuts, screws, washers), 7320 (springs), 7321 (stoves, ranges, cookers), 7323 (table and kitchen articles), 7324 (sanitary ware), 7325 (cast articles), and 7326 (other articles of iron or steel — the residual heading). The distinction between Chapters 72 and 73 is critical for Section 232: most Chapter 72 products are subject to the 25% tariff, and many Chapter 73 products are as well, but some finished articles in Chapter 73 may be excluded.

Antidumping and Countervailing Duties on Metals

Beyond Section 232, metals are one of the product categories most heavily affected by antidumping and countervailing duty (AD/CVD) orders. There are active AD/CVD orders on steel products from dozens of countries, covering products ranging from hot-rolled steel flat products to steel nails, wire rod, and structural steel beams. These orders impose additional duties — sometimes exceeding 200% — on products from specific countries. The scope of an AD/CVD order is defined by the product description in the order, not by the HTS code, but in practice the two are closely related. Importers must check whether their specific product from a specific country is covered by an active AD/CVD order. This requires matching the product characteristics against the scope language of each order and paying any applicable cash deposits at the time of entry. Classification errors that result in failing to identify AD/CVD exposure create serious legal liability.

Critical Metal Classification Mistakes

1. Misidentifying the steel type: Non-alloy, stainless, and other alloy steel classify under different heading ranges within Chapter 72. A mill test certificate is essential to determine the correct category.
2. Confusing Chapter 72 with Chapter 73: Semi-manufactured forms (sheets, bars, wire) are in Chapter 72; finished articles (structures, fasteners, containers) are in Chapter 73. The boundary affects Section 232 applicability.
3. Ignoring dimensional thresholds: Many subheadings within the flat-rolled steel headings depend on thickness and width. A product that is 4.75mm thick classifies differently from one that is 4.76mm thick.
4. Overlooking AD/CVD orders: With hundreds of active orders covering steel products, failing to check AD/CVD scope for every import is a compliance failure waiting to happen.
5. Misclassifying downstream products: A steel article that has been further worked (machined, welded into an assembly, coated) may no longer classify in Chapters 72-73 and may not be subject to Section 232.
6. Assuming all metal articles are Section 232: The presidential proclamations define specific HTS headings covered by Section 232. Not all metal products are included, and exclusions are available for certain products.

“In the metals trade, classification is not just a compliance exercise — it is a strategic business decision. The difference between Chapter 72 and Chapter 73, between alloy and non-alloy, between one thickness and another, can mean tens of thousands of dollars per shipment in duty costs.”

— American Institute for International Steel