Other, not further worked than hot-rolled, not in coils

CN code 7225 40 covers flat-rolled products of alloy steel other than stainless steel, with a width of at least 600 mm, produced by hot-rolling and not supplied in coils. Within Chapter 72, Note 1(f) distinguishes several categories of alloy steel: stainless steel, electrical silicon steel, high-speed tool steel and other alloy steels. Tool steel is characterised by a chemical composition engineered for cutting, forming or high-temperature applications: it typically contains elevated carbon levels above 0.6% and additions of tungsten, molybdenum, chromium or vanadium that confer hardness and wear resistance. Correct classification requires a full chemical analysis, as commercial grade designations alone may not be sufficient for customs purposes. Flat-rolled tool steel products not in coils are typically heavy plates cut to size, used in die-making, injection moulding and industrial tooling applications.

Flat-rolled tool steel products classified under 7225 40 are subject to CBAM as steel products with high embedded CO2 emissions. From 1 January 2026, importers must purchase CBAM certificates for each tonne of CO2 equivalent embedded in the imported product. Tool steel, often produced in electric arc furnaces with high alloy additions, typically has higher embedded emissions than ordinary carbon steel, making CBAM certificate costs proportionally greater. Importers should request detailed emissions data from producers in the format prescribed by the Commission Implementing Regulation. Where producer data is unavailable, the Commission default values apply; these are typically set conservatively above average actual emissions, potentially resulting in excess costs. Developing supplier relationships that include emissions reporting capability is becoming an important element of supply chain management.

Hot-rolled tool steel flat products are subject to EU steel safeguard measures. The quarterly TRQ system applies zero additional duty within the allocated quota, with a 25% safeguard duty charged once the quota is exhausted. Tool steel products from China may additionally be subject to anti-dumping or countervailing duties accumulating with the safeguard measure. Chemical composition and production method documentation is frequently scrutinised by customs authorities, as tool steel may be confused with other alloy steels. The EU embargo on steel products originating in Russia and Belarus encompasses tool steel, and border controls have been strengthened. Importers should ensure precision in the SAD declaration, particularly regarding the CN code, country of origin and customs value, to avoid post-clearance adjustments.

CN code 7225 40 classifies tool steel flat-rolled products hot-rolled within Chapter 72 of the Combined Nomenclature. Steel imports into the EU are subject not only to standard TARIC duty rates but also to safeguard measures in the form of tariff-rate quotas. Once the quota volume is exceeded, an additional 25% duty applies. Importers must correctly declare the country of origin, as preferential tariff rates may apply under EU free trade agreements. Anti-dumping duties may also be in force for certain origins. Import VAT is charged on the customs value plus all duties payable.