2pcs Hollow Arc Comb
CN β USAI Analysis
πͺ 2pcs Hollow Arc Comb (Hair Styling Tools)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Compliance Strategy
π I. Product Definition & Classification: Do You Really Know What a "Hollow Arc Comb" Is?
A Hollow Arc Comb (often referred to as a "round brush," "thermal round brush," or "curly hair comb") is a specialized hair styling tool used to create volume, curls, or smoothness in hair. It typically features a cylindrical core with vents (hollows) to allow heat from a hair dryer to pass through, accelerating drying and styling.
In international trade, these are not classified as simple "hair brushes" but rather as electric or non-electric hair styling appliances/tools, depending on whether they have an integrated heating element.
β οΈ Key Distinction Point:
- If it is a passive tool (no electricity, no heating element, just plastic/metal/bristles) β Classified under Hair Styling Tools (HS 9615).
- If it has an integrated heating coil/electric motor (self-heating curling tool) β Classified under Electrical Hair Appliances (HS 8516).π Common Misclassification Error:
Many exporters mistakenly classify hollow arc combs under HS 9603.90 (Other brushes), which has different duty rates and inspection requirements. This is incorrect for styling-specific tools with specific shapes (cylindrical/arc).
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Match)
| HS Code | Product Description | Applicable Scenario | Electric/Heating? |
|---|---|---|---|
9615.19.00.00 |
Combs, hair-treatment forks and the like (other than hair-dressing combs of section VII) and parts thereof, of hard rubber or plastics | Most common hollow arc combs (plastic core, nylon/bristle pins, no heat) | β No |
9615.90.90.00 |
Other combs, hair-treatment forks and the like | Wooden, metal, or mixed-material hollow arc combs | β No |
8516.32.00.00 |
Electrical hair dryers and hair curlers and other appliances for trimming, cutting, curling, waving, washing or drying the hair | Electric hollow arc combs with self-heating elements | β Yes |
9603.90.99.90 |
Brooms, brushes... made up into rugs or mats; paint pads and rollers; squeegees... | Incorrect classification for styling brushes | β Wrong |
π Key Reminder:
- Most "Hollow Arc Combs" sold on Amazon/e-commerce platforms are passive tools (heated by a separate hair dryer). They must be classified under HS 9615.
- If the product description includes "self-heating," "electric," or "AC/DC input," it must go under HS 8516.32.00.00.
- The term "2pcs" is a packaging quantity and does not affect the HS code; each unit is assessed individually.
π° III. 2026 Latest Tariff Rate Details (Including Surcharges)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Time: Post-November 10, 2025 (Current IEEPA & USITC Rules)
π― 1. 9615.19.00.00 ββ Plastic Hollow Arc Combs (Non-Electric)
| Item | Content |
|---|---|
| Base Duty Rate | 5.7% (Ad Valorem) |
| USITC Additional Duty (Section 301) | +25% (Footnote 9903.01.02) |
| IEEPA Additional Duty (China) | +10% (Applicable to certain plastic articles/tools) |
| Total Effective Rate | ~40.7% (Calculated on CIF Value) |
| De Minimis Exemption | β Not Eligible (Deny De Minimis for Section 301 items >$800) |
| Legal Basis Path | USITC:9615.19.00.00 β FOOTNOTE:9903.01.02 β IEEPA:9903.01.25 |
π Explanation:
- The base rate for plastic combs (9615.19) is relatively low at 5.7%.
- However, due to Section 301 tariffs (25%) and IEEPA surcharges (10%), the total cost impact is significant.
- Note: Some plastic articles may be exempt from IEEPA if they fall under specific exclusions, but general hair styling tools are not currently exempt.
π― 2. 9615.90.90.00 ββ Other Materials (Wood/Metal)
| Item | Content |
|---|---|
| Base Duty Rate | 3.4% (Ad Valorem) |
| USITC Additional Duty (Section 301) | +25% |
| IEEPA Additional Duty | +10% (If applicable) |
| Total Effective Rate | ~38.4% |
| De Minimis Exemption | β Not Eligible |
π Note:
- Wooden combs have a lower base rate but still face the full Section 301 burden.
- Metal combs may fall under 7323 (Tableware/Kitchenware) if they have specific uses, but for hair styling, 9615 is the correct heading.
π οΈ IV. Customs Clearance Practical Advice (Operational Pitfall Guide)
β 1. Documentation Checklist (Essential Items)
| Document | Required | Description |
|---|---|---|
| β Product Specifications | βοΈ | Material (Plastic/Wood/Metal), Diameter, Bristle Type (Nylon/Badger/Boar), Electric/Non-Electric |
| β Product Images | βοΈ | Clear front, side, and back views. Show bristle structure. |
| β Commercial Invoice | βοΈ | Must clearly state "Hollow Arc Comb for Hair Styling" (Avoid generic "Comb") |
| β Material Declaration | βοΈ | Specify plastic type (PP/ABS) or wood type to determine HS 9615.19 vs 9615.90 |
| β FCC/CE Certification | β οΈ If Electric | If classified under 8516, FCC is mandatory for US import. For passive tools (9615), not required but recommended for quality proof. |
| β Packing List | βοΈ | Indicate "2pcs per set" or "2pcs per box" as appropriate for unit price calculation |
β 2. Declaration Tips (Key Mnemonics)
π₯ "Non-Electric is 9615, Electric is 8516. Don't mix them up, or customs will delay!"
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Passive Plastic Comb | 9615.19.00.00 "Plastic Hollow Arc Comb for Hair Styling" |
Misdeclare as "Hairbrush" (9603) β Risk of penalty |
| Passive Wooden Comb | 9615.90.90.00 "Wooden Hair Styling Comb" |
Misdeclare as "Household Tool" |
| Electric Self-Heating Comb | 8516.32.00.00 "Electric Hair Curler/Styling Tool" |
Never declare electric tools as 9615! (FCC violation + Misclassification) |
| Set of 2pcs | Declare as one unit if sold as a set, or two units if identical. Ensure unit price reflects quantity. | Split invoice artificially to lower unit value β High audit risk |
β 3. Special Situations Handling
| Situation | Handling Advice |
|---|---|
| OEM Custom Colors/Logos | Provide OEM agreement or authorization letter if brand is registered. |
| Branded Products | Ensure IP clearance (Amazon Brand Registry) to avoid IPR seizures. |
| Mixed Materials (Plastic+Bristles) | Still classified as 9615.19 (Plastic) because the handle/core defines the article. |
| Gift Sets (Comb + Hair Ties) | If hair ties are incidental, the whole set may be classified under 9615. If hair ties are significant, separate HTS codes may apply, but usually 9615 dominates for hair styling kits. |
π V. Global Market Clearance Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Duty Rate | Certification Requirements | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 9615.19.00.00 |
~40.7% (with surcharges) | None for passive; FCC for electric | High duty burden due to Section 301 |
| π¨π³ China | 9615.19.00.00 |
6.5% | CCC (only if electric) | Low duty for imports |
| πͺπΊ EU | 9615.19.00.00 |
4.4% | CE (only if electric) | No major surcharges |
| π¬π§ UK | 9615.19.00.00 |
4.4% | UKCA (only if electric) | Post-Brexit rules apply |
| π¦πΊ Australia | 9615.19.00.00 |
5.0% | RCM (only if electric) | No major surcharges |
π Conclusion:
- USA remains the most expensive market due to Section 301 + IEEPA tariffs.
- Passive combs (9615) are easier to clear than electric ones (8516) regarding certifications, but the duty cost is similar due to surcharges.
- Electric combs require FCC/CE/UL certificates. Without them, goods will be detained at US Customs.
π VI. Common Mistakes & Pitfalls (Lessons Learned)
β Mistake 1: Declaring electric hollow combs as 9615.19 (Non-Electric)
π Consequence: Customs will demand FCC certificates upon entry. Without them, goods will be seized or returned.
β Mistake 2: Using "Hair Brush" (HS 9603) for styling combs
π Consequence: HS 9603 has different duty rates and inspection codes. Misclassification can lead to fines and delays.
β Mistake 3: Ignoring "2pcs" packaging in unit price calculation
π Consequence: If the invoice says $10 for 2pcs, but the customs value is calculated per piece, it may trigger price scrutiny. Ensure unit price is clearly defined per comb.
β Mistake 4: Claiming "De Minimis" for Section 301 items
π Consequence: Section 301 goods do not qualify for de minimis exemption ($800). Attempts to split shipments will be flagged.
β Correct Practice:
"2pcs Plastic Hollow Arc Hair Styling Combs, Model XYZ, Non-Electric, ABS Plastic Body, Nylon Bristles, FCC Not Required, HS 9615.19.00.00"
π― VII. Conclusion: Professional Declaration Saves Money!
π― Remember the Golden Rules:
πΉ "Passive = 9615, Electric = 8516. Never mix!"
πΉ "Section 301 hits all combs. Check your margin!"
πΉ "FCC is mandatory for electric. Don't risk it!"
π Pro Tip:
If your hollow arc combs are not manufactured in China (e.g., made in Vietnam or Thailand), you may avoid Section 301 tariffs.
β Action: Source from non-China origins or verify Substantial Transformation rules to change Country of Origin.
π£ Immediate Action:
π Verify if your product is Electric or Passive
π Prepare FCC Certificates if Electric
π Calculate Total Landed Cost (CIF + ~40% Duty) to ensure profitability before shipping.
β¨ Precise Classification is the Key to Smooth Customs Clearance!
πΌ Every percentage point of duty savings is pure profit!
Customer Reviews
About HS Code Classification
The Harmonized System (HS) is an internationally standardized nomenclature developed by the World Customs Organization (WCO) to classify traded products. Over 200 countries use the HS system as the basis for customs tariffs, trade statistics, and import/export regulations.
Each HS code follows a hierarchical structure:
- Chapter (2 digits) β Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) β More specific grouping within the chapter
- Subheading (6 digits) β Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) β Country-specific extensions for further classification, such as US HTSUS 10-digit codes
Correct HS code classification is essential for smooth customs clearance, accurate duty payment, and compliance with trade regulations. Misclassification can lead to customs delays, overpayment of duties, or penalties.
When importing from CN to US, the applicable tariff rates may include:
- Most-Favored-Nation (MFN) rate β The standard duty rate applied to WTO members
- General rate β Applied to countries without trade agreements
- Trade remedy duties β Additional tariffs such as Section 301 (anti-dumping), Section 232 (national security), or countervailing duties
The information provided on this page is for reference purposes only. For official classification, please consult with your local customs authority or a licensed customs broker.