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Cold-rolled alloy steel coils with 25% nickel: which subheading?

April 2026 examClassificationQuestion 32 of 80

Of the four choices below, which is the best CLASSIFICATION of alloy steel coils? The cold-rolled steel is successively superimposed in coils and measures 1220 mm in width and 3.75 mm in thickness. The steel chemistry consists of 0.15% Carbon, 0.7 % Titanium, and 25% Nickel. The coils have not been further worked than cold-rolled.

How to get there

Steel classification is a chain of definitions from the Chapter 72 notes. Work through them in order.

1. Alloy or non-alloy? Alloy.

Chapter 72 Note 1(f): Other alloy steelSteels not complying with the definition of stainless steel and containing by weight one or more of the following elements in the proportion shown: … 0.3 percent or more of nickel … 0.05 percent or more of titanium …

25% nickel and 0.7% titanium both clear the thresholds easily, so this is alloy steel.

2. Stainless? No.

Chapter 72 Note 1(e): Stainless steelAlloy steels containing, by weight 1.2 percent or less of carbon and 10.5 percent or more of chromium …

There's no chromium in the chemistry, so it's "other alloy steel" (headings 7224–7229), not stainless (7218–7223).

3. Shape and width: flat-rolled, 600 mm or wider → 7225

Coils of successively superimposed layers are flat-rolled products (Note 1(k)). At 1220 mm wide, it's heading 7225 (other alloy steel, 600 mm or wider), not 7226 (under 600 mm).

4. Down the subheadings (GRI 6)

HTSUS 7225.50Other, not further worked than cold-rolled (cold-reduced):
  7225.50.11 Of tool steel
  Other: 7225.50.60 Of a thickness of 4.75 mm or more
    Of a thickness of less than 4.75 mm: 7225.50.70 Heat-resisting steel · 7225.50.80 Other
      7225.50.80.10 Of high-nickel alloy steel
  • Cold-rolled, not further worked → 7225.50.
  • Not tool steel.
  • 3.75 mm, under 4.75 mm → not .60.
  • Not heat-resisting: that needs 4% to under 10.5% chromium (Note 1(g)), and there's none → .80.
  • High-nickel: Statistical Note 1 defines high-nickel alloy steel as alloy steel with 24% or more nickel. At 25%, it's .8010.

Answer: 7225.50.8010, C.

Why the other choices are wrong

A) 7209.15.0000: heading 7209 is for iron or non-alloy steel. With 25% nickel and 0.7% titanium, this is alloy steel.
B) 7219.32.0035: heading 7219 is stainless steel, which needs at least 10.5% chromium. There's none.
D) 7226.99.0130: heading 7226 covers alloy flat-rolled products under 600 mm wide. These coils are 1220 mm. (That statistical line is also for zinc-plated products.)
Tip
Steel checklist: (1) alloy? (Note 1(f) thresholds) → (2) stainless? (≥10.5% Cr) → (3) shape (flat-rolled, bar, wire …) → (4) width (600 mm) → (5) how it was worked (hot, cold, clad, plated) → (6) thickness (4.75 mm and 3 mm splits) → (7) statistical notes (high-nickel ≥24% Ni).

Sources: HTSUS Chapter 72 Notes 1(e), 1(f), 1(g), 1(k) and Statistical Note 1; headings 7209, 7219, 7225, 7226; subheadings 7225.50.11–7225.50.80.80 (USITC HTS). CBP key: 7225.50.8010, HTSUS; GRI.

CBP answer key: Answer C · 7225.50.8010, HTSUS; HTSUS General Rule of Interpretation (GRI) 1; Chapter 72, Note 1(f); Chapter 72, Note 1(k); Chapter 72, Additional U.S. Note, 2; Chapter 72, Statistical Note 1Source: CBP past exams ↗