HTS 7218 vs 7219: Stainless Billet, Slab, or Flat Product

These two chapter-72 headings catch most stainless steel imports into the US. The line between them is the rolling step. Get it right and Section 232 applies to the actual flat product you are buying. Get it wrong and you either over-pay duty on semi-finished mill-direct material or under-pay on a flat-rolled coil that should have been the higher line.

This guide walks through what each heading covers, where the classification gets ambiguous, the worked-example impact of misclassification, and the documentation that supports the call.

7218: stainless ingots, other primary forms, semi-finished

Heading 7218 covers stainless steel that has not yet been rolled into flat or long product. The subheadings:

• 7218.10: Ingots and other primary forms. Cast in any shape directly from the melt, prior to any rolling, forging, or further hot work.
• 7218.91: Semi-finished of rectangular (other than square) cross section. This is the slab line. Continuously cast slab destined for the hot strip mill lives here.
• 7218.99: Semi-finished of other cross sections. Round or square billet, bloom, or other near-net shapes destined for rolling into bar, rod, or long product.

The defining test is shape and stage. Continuously cast slab is 7218.91 because it has not yet been rolled. Once that slab enters the hot strip mill and comes out as a hot-rolled coil, the classification jumps to 7219.

7219: stainless flat-rolled product

Heading 7219 covers all flat-rolled stainless steel of a width 600 mm or more. The subheadings split by surface finish and by thickness band:

• 7219.11 to 7219.14: Hot-rolled, not in coils, of various thickness bands.
• 7219.21 to 7219.24: Hot-rolled in coils.
• 7219.31 to 7219.35: Cold-rolled (cold-reduced).
• 7219.90: Other.

If your stainless flat product is less than 600 mm wide, it belongs in heading 7220 (narrow flat-rolled stainless), not 7219. That is a different decision tree and adds a second classification trap.

Worked example: misclassifying slab as flat-rolled

Suppose an importer buys 200,000 USD of Indonesian-origin stainless slab, continuously cast at a mill in Morowali, intended to be hot rolled into coil at a US service center. The mill ships the slab uncoiled, in the as-cast state.

Correct classification: HTS 7218.91.0030 (semi-finished, rectangular, of high-nickel content).

Incorrect classification: HTS 7219.13.00 (hot-rolled, in coils, 4.75 mm or more thick).

The flat-rolled line is also Section 232, so the duty looks the same. But the entry is wrong. CBP can issue a 1592 notice for negligent or intentional misclassification, regardless of whether the duty paid was lower or the same. The penalty for negligent misclassification can be up to two times the duty loss or four times the value of the merchandise for fraud.

A buyer who classifies slab as 7219 to "match the eventual product" creates a 1592 exposure on every entry without changing the duty. There is no upside. Always classify at the moment of importation, not at the moment of intended end use.

Worked example: cold-rolled coil from Korea

A US service center imports 500,000 USD of Korean cold-rolled stainless coil, 1500 mm wide, 1.5 mm thick.

Correct classification: HTS 7219.34.0030 (cold-rolled, 0.5 mm but less than 3 mm thick, of width 600 mm or more).

Effective rate 50.25 percent. KORUS gives the MFN preference but cannot touch the Section 232 layer.

Where the call gets ambiguous

Three cases come up in practice.

1. Hot-rolled black coil with mill scale, not yet pickled. Still flat-rolled, still 7219.21 or 7219.22 depending on thickness. The mill-scale state does not push it back into 7218.

2. Cut-to-length sheet versus plate. Flat-rolled stainless cut to length is still 7219.11 to 7219.14 (not in coils) at the matching thickness band. It is not stainless steel plate of chapter 73.

3. Forged billet versus cast billet. Both are 7218.99. The mode of primary forming does not change the heading. The mill cert distinguishes the casting from the forging, but for the HS code they are the same line.

Documentation that supports the classification

CBP looks for the following to substantiate any stainless steel HTS call:

• Mill test report (MTR) identifying the heat number, the chemistry, the mode of primary forming (cast or forged), and the state at shipment (as-cast, hot-rolled, cold-rolled).
• Commercial invoice description that uses the heading-defining vocabulary (ingot, slab, billet, bar, hot-rolled coil, cold-rolled coil, sheet, strip, plate).
• Photographic or video documentation in some high-value entries.
• For 232 purposes, the smelt-and-pour certificate identifying the country where the steel was melted and where it was first cast.

Run your stainless shipment now

The LandedFees calculator covers chapter 72 with the current Section 232 stack, USMCA and KORUS preferences, and the 1592 misclassification flag built into the classifier prompt. If your description does not clearly fit the heading our engine picks, you see a needs-human-review flag before the entry is filed.

Calculate a stainless steel shipment

Section 122 status as of June 20 2026

The May 7 2026 Court of International Trade ruling in Oregon v. United States (consolidated with Burlap and Barrel v. United States) struck down the Section 122 proclamation. The Federal Circuit issued an administrative stay on May 12 2026, so CBP is still collecting the duty pending appeal. Importers paying now should preserve protest rights and refund claims in case the government loses on the merits. The underlying Section 122 authority sunsets July 24 2026 under the statutory 150-day ceiling, regardless of the appeal outcome, unless Congress extends or a fresh proclamation restarts the clock.

Citations

• USITC Harmonized Tariff Schedule chapter 72: https://hts.usitc.gov/?query=7218
• USITC Harmonized Tariff Schedule chapter 72: https://hts.usitc.gov/?query=7219
• Section 232 proclamation increasing steel and aluminum to 50 percent (June 2025): Federal Register
• 19 USC 1592 (penalties for misclassification): https://www.cbp.gov/trade/programs-administration/penalties/1592
• USMCA chapter rule of origin for chapter 72: USMCA Annex 4-B