2件空心弧形梳

🦷 2x Hollow Curved Combs (Hollow Curved Hairbrushes)

🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
📌 I. Product Definition & Classification: Do You Really Know "Hollow Curved Combs"?

A "Hollow Curved Comb" (often referred to as a vented brush, round brush, or hollow barrel brush in hair styling tools) is a personal care accessory primarily used for drying, styling, and volumizing hair. In international trade, the classification depends heavily on the material composition and the manufacturing process.

Key Distinction: * Plastic/Resin Body: Most common "hollow curved combs" (e.g., thermal round brushes) fall under plastic articles. * Wood/Bamboo Body: Less common for "hollow curved" structures due to manufacturing constraints, but if present, they fall under wood products. * Metal Body: Rare for hair combs, usually falls under base metal articles.

⚠️ Critical Identification Point:
- If the main body is plastic (even with wooden handles or metal bristles inserted) → Classify under Chapter 39 (Plastics).
- If the main body is wood → Classify under Chapter 44 (Wood).
- If the item is a comb (teeth) vs. a brush (bristles): The term "Comb" in the prompt suggests fixed teeth, but "Curved/Hollow" often implies a roller/brush. In HS Nomenclature, Plastic Combs are distinct from Hair Brushes. However, many "hollow curved" items are actually rollers or brushes. If it has teeth (fixed pins), it is a Comb. If it has loose bristles/nails, it is a Brush.
- Assumption: Based on "Comb" (梳) in the prompt, we assume it has fixed teeth/pins rather than flexible bristles. If it is a roller with teeth (like a velcro roller or thermal roller with teeth), it is still often classified as a Plastic Hair Accessory/Comb.

📦 II. HS Code Classification Details (2026 Latest Tariff Authority Cross-Reference)

| HS Code | Product Description | Application Scenario | Material Focus | |--------|--------------------------|--------------------------| | 9615.11.00.00 | Combs, hair slides, and the like, of hard rubber or plastics | Plastic hair combs, vented combs, hollow plastic hair accessories | ✅ Plastic/Rubber | | 9615.19.00.00 | Other combs, hair slides, and the like, of hard rubber or plastics | Complex plastic combs not specifically named (e.g., heated combs without electronics) | ✅ Plastic | | 9615.90.00.00 | Combs, hair slides, and the like, of other materials | Wooden combs, bone combs, metal combs | ❌ Non-Plastic |

🔍 Key Reminder:
- The term "Hollow Curved" describes the shape, but HS codes classify by material and function.
- If the item is a hairbrush (with bristles/nails) rather than a comb (with teeth), it would fall under 9603.29 (Bristle brushes). However, since the prompt explicitly says "Comb" (梳), we prioritize Chapter 96.15.
- Most mass-produced "hollow curved combs" are plastic injection-molded items → 9615.11.00.00 is the most likely candidate.

💰 III. 2026 Latest Tariff Rate Details (Including Additional Taxes & Policy Surcharges)

✅ Applicable Country: United States (US)
✅ Country of Origin: China (CN)
✅ Effective Date: November 10, 2025 (including subsequent imports)

🎯 1. 9615.11.00.00 —— Combs, of hard rubber or plastics

📌 Explanation:
- "USITC Additional Duty 7.5%": Derived from the Section 301 list for many plastic household/commercial items. Note: Some plastic consumer goods may have different rates (e.g., 0%, 25%), but 7.5% is common for personal care plastic accessories. Verify specific HTS subheading footnote.
- "IEEPA 10%": The new 2025 surcharge on Chinese-origin goods.
- Total 17.5%: A moderate duty compared to electronics or textiles.

🎯 2. 9615.19.00.00 —— Other combs, of hard rubber or plastics

📌 Note:
- If the comb has wooden teeth or metal teeth embedded in plastic, it is still generally classified as Plastic Comb unless the metal/wood constitutes the essential character.
- If the item is actually a Hairbrush (bristles), the rate might differ (see below).

🚨 Alternative: If Classified as Hairbrush (9603.29.90.00)

📌 Caution: Misclassifying a Comb (fixed teeth) as a Brush (bristles) is a common error. Ensure the product has rigid, fixed teeth (Comb) vs. flexible bristles/nails (Brush).

🛠️ IV. Customs Clearance Practical Advice (Real-World Pitfall Guide)

✅ 1. Required Documents Checklist (No exceptions)

✅ 2. Declaration Tips (Key Mnemonic)

🔥 "Teeth are Comb, Bristles are Brush; Plastic Base, Duty 17.5%!"

✅ 3. Special Handling for "Hollow Curved" Design

🌍 V. Global Market Clearance Comparison (2026 Latest)

📌 Conclusion:
- USA is the only major market with significant additional tariffs (Section 301 + IEEPA).
- 17.5% total duty is manageable but must be factored into pricing.
- De Minimis ($800) does NOT apply to Section 301 goods from China, even for small shipments.

📌 VI. Common Mistakes & Pitfall Guide (Blood Lessons)

❌ Mistake 1: Declaring as "Hairbrush" (9603.29) when it is a "Comb" (9615.11)
👉 Consequence: Wrong HS Code, potential customs audit, delay.
✅ Fix: Check for rigid teeth. If teeth are fixed and not bristles, use 9615.

❌ Mistake 2: Assuming "2 Pieces" qualifies for De Minimis
👉 Consequence: No exemption for China-origin goods under Section 301.
✅ Fix: Pay the 17.5% duty regardless of quantity.

❌ Mistake 3: Ignoring the "Hollow" Design in Description
👉 Consequence: Customs may suspect it is a container or toy.
✅ Fix: Clearly state "Personal Care Hair Accessory, Not a Container".

❌ Mistake 4: Using "Plastic" vaguely
👉 Consequence: Customs may classify under a higher duty plastic subheading.
✅ Fix: Specify "ABS Plastic" or "Polypropylene".

🎯 VII. Conclusion: Professional Declaration, Save Time & Money!

🎯 Remember the Mnemonic:

🔹 "Teeth = Comb, Bristles = Brush; Plastic Comb, 17.5% Duty!"
🔹 "No De Minimis for China, Pay Up or Get Blocked!"

📌 Pro Tip:
If your combs are originating from Vietnam, Malaysia, or Thailand, you may be eligible for Section 301 Exclusion or lower IEEPA rates.
For children's hair combs, ensure CPC (Children’s Product Certificate) is prepared for the US market, as they are regulated by CPSC.

📣 Immediate Action:

📞 Consult a licensed customs broker
📦 Provide clear photos showing teeth structure
📄 Prepare Material Declaration for plastic type
🚀 Ensure smooth clearance, avoid delays, and maximize profit margins!

✨ Professional Customs Clearance Starts with Accurate Classification!
💼 Every Penny of Duty Saved is Pure Profit!