NCS/ARS/CL/10379

You have applied for the tariff classification of Prime Painted Zinc-Aluminium-Magnesium Alloy Coated Steel Coils, imported in coil form and packaged either eye-to-wall or eye-to-horizon (horizontal).

PRODUCT ANALYSIS

The product under consideration is a flat-rolled product of non-alloy steel that has been continuously coated by the hot-dip process with a zinc-aluminium-magnesium (Zn-Al-Mg) alloy to provide enhanced corrosion protection. The Zn-Al-Mg coating offers superior atmospheric corrosion resistance, improved protection at cut edges, and extended service life, particularly in aggressive environmental conditions.

Following the metallic coating process, the steel is further finished with a durable synthetic paint system, producing a pre-painted steel product suitable for applications requiring both long-term corrosion resistance and an attractive decorative finish. The paint coating also enhances resistance to ultraviolet (UV) radiation, weathering, abrasion, and chemical exposure.

According to the documentation submitted, the product bears the following specification:

0.47 TCT × 400 ZINCALUME® ULTRA AM-Activate™ G300 Resin Clear

This specification denotes the following characteristics:

• 0.47 TCT (Total Coated Thickness): Overall thickness of 0.47 mm, including the base steel, metallic coating, primer, paint and protective coating.
• 0.42 mm BMT (Base Metal Thickness): Thickness of the steel substrate before application of the metallic and paint coatings.
• 400 mm: Width of the steel coil.
• ZINCALUME® ULTRA AM-Activate™: A proprietary hot-dip zinc-aluminium-magnesium (Zn-Al-Mg) alloy-coated steel produced using BlueScope's patented AM-Activate™ technology. The coating is specifically designed to provide enhanced corrosion resistance, particularly at cut edges and in aggressive environments. According to the submitted technical documentation, the product is manufactured to the AM125 metallic coating standard, which comprises approximately 55% aluminium, 2% magnesium and the balance zinc, making it particularly suitable for roofing, wall cladding and other external building applications requiring long-term corrosion protection.
• G300: Structural-grade steel having a minimum yield strength of 300 MPa, suitable for roofing, wall cladding, roll-forming and light structural applications.
• Resin Clear: A transparent resin-based protective topcoat applied over the painted surface to improve gloss retention, scratch resistance, weatherability and long-term durability without altering the underlying colour.

The product is supplied in coils for subsequent manufacture into roofing sheets, wall cladding, rainwater goods, fencing and other building products. The metallic alloy coating and paint system serve primarily as protective and decorative finishes and do not alter the essential character of the underlying steel substrate.

Based on the Mill Test Certificate and other supporting documents submitted, the steel substrate has the following chemical composition:

The relatively low carbon content, together with controlled levels of manganese, phosphorus and sulphur, indicates that the substrate is a low-carbon structural steel possessing an appropriate balance of strength, ductility, weldability and formability, consistent with the mechanical requirements of G300 structural steel.

TARIFF CLASSIFICATION

Note 1(k) to Chapter 72 defines flat-rolled products as:

"Rolled products of solid rectangular (other than square) cross-section, in the form of:

• coils of successively superimposed layers; or
• straight lengths which, if of a thickness less than 4.75 mm, are of a width measuring at least ten times the thickness or, if of a thickness of 4.75 mm or more, are of a width exceeding 150 mm and measuring at least twice the thickness."

In addition, the Explanatory Note to Chapter 72, Part (C)(2)(d), recognizes products that have undergone surface treatment, including coating, plating and painting.

The product is a flat-rolled product of non-alloy steel, measuring 400 mm in width, continuously hot-dip coated with a zinc-aluminium-magnesium alloy and subsequently painted. The paint coating is an additional protective and decorative finish and does not change the essential character of the product as metallic-coated flat-rolled steel.

Accordingly, the product satisfies the terms of heading 72.12, which covers:

"Flat-rolled products of iron or non-alloy steel, of a width of less than 600 mm, clad, plated or coated."

Furthermore, the Subheading Explanatory Note to heading 72.12 provides that the heading covers the same categories of products as heading 72.10, except that the products must be of a width of less than 600 mm.

The Subheading Explanatory Notes to heading 72.12 further refer to the Explanatory Notes to the subheadings of heading 72.10 for products that have been subjected to more than one type of coating, plating or cladding. The submitted technical documentation confirms that the product is manufactured by the hot-dip coating process using a zinc-aluminium-magnesium alloy (AM125), followed by the application of a paint coating. The presence of the aluminium-magnesium alloy coating confirms that the product is not electrolytically coated but is a hot-dip metallic-coated steel product.

Since the product is of non-alloy steel, flat-rolled, less than 600 mm in width, and otherwise coated with zinc-based metallic coating followed by painting, it is properly classified under tariff subheading 7212.30.00.00 – Otherwise plated or coated with zinc, at 5% rate of duty and 7.5% VAT in accordance with the ECOWAS Common External Tariff (CET) 2022–2027.

LEGAL JUSTIFICATION

• GIR 1 and 6 
• Note 1(k) to Chapter 72
• The terms of heading 72.12 and subheading 7212.30, together with the relevant Harmonized System Explanatory Notes.