Hot-rolled steel is processed above the metal's recrystallization temperature, producing a scaled surface finish suitable for structural and heavy fabrication uses. Cold-rolled steel is further reduced at room temperature, yielding tighter dimensional tolerances and a smoother surface preferred for automotive panels and appliances. The two forms are classified under different HTS headings and have historically been subject to separate antidumping investigations, so the distinction has direct duty implications.

For Section 232 purposes, the country of origin of steel articles is generally the country where the steel was melted and poured, not where subsequent rolling or drawing occurred. A cold-rolling operation in a third country does not change the Section 232 origin of the underlying steel substrate. Importers relying on third-country processing should obtain mill certificates tracing the steel to its original melt source.