Detachable Paint Brush
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3926906090 | 39.2% | CN | US | Official Doc |
| 8205517500 | 38.7% | CN | US | Official Doc |
| 3926909989 | 22.8% | CN | US | Official Doc |
| 9603908050 | 70.3% | CN | US | Official Doc |
| 9603404060 | 14.0% | CN | US | Official Doc |
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AI Analysis
ποΈ Detachable Paint Brush (Removable Head/Handle Systems)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Breakdown | Professional Level Clearance Strategy
π Part 1: Product Definition & Classification: Do You Really Understand a "Detachable" Brush?
A "Detachable Paint Brush" typically refers to a painting tool where the brush head (bristles/hair) and the handle are separate entities. This design allows for replaceable heads, ergonomic handling, or specialized industrial application.
In international trade, classification depends heavily on material composition and functional specificity:
1. Plastic-Handle Systems: If the "detachable" part implies a plastic handle mechanism combined with a generic brush or plastic accessory. 2. Metal/Composite Handles with Specific Bristles: If the product is strictly a painting tool with a specific mechanical interface for the head. 3. Generic Tools: If the detachability makes it a general-purpose hand tool rather than a specialized painting instrument.
β οΈ Key Distinction Point:
- Is it a specialized painting tool (e.g., for house paint, varnish)? β Look at Chapter 96 (Brooms, Brushes).
- Is it a general plastic implement or tool? β Look at Chapter 39 (Plastics) or Chapter 82 (Tools).
- Crucial Detail: The presence of "Paint" in the name does not automatically guarantee Chapter 96 if the primary material or function shifts (e.g., if it's a plastic applicator pad rather than bristles).
π¦ Part 2: HS Code Classification Details (2026 Latest Tariff Authority Comparison)
Based on the provided data, here are the 5 possible classifications for a "Detachable Paint Brush" and the logic behind them.
| HS Code | Product Description (Summary) | Applicable Scenario | Key Classification Logic |
|---|---|---|---|
3926.90.60.90 |
Other plastic articles (Plastic Material) | Detachable handle/body made primarily of plastic; non-specific utility | Classified under Chapter 39 because the core structure is plastic, not a traditional bristle brush. |
8205.51.75.00 |
Other hand tools (Household Tools) | A metal/plastic tool used for household painting tasks, classified as a "hand tool" rather than a brush | Classified under Chapter 82 because it functions as a general "hand tool" in a household context. |
3926.90.99.89 |
Other articles of plastics | Contains plastic materials; generic "other" plastic product | A fallback for plastic-based applicators that don't fit specific sub-categories. |
9603.90.80.50 |
Paint pads, rollers, and related brushes | Industrial or specialized painting applicators (pads/rollers) | Classified under Chapter 96 but as a specialized painting accessory (pad/roller type), not a traditional bristle brush. |
9603.40.40.60 |
Brushes for applying paint, varnish, etc. | Traditional bristle/synthetic fiber brushes designed specifically for painting | Classified under Chapter 96 as a dedicated painting brush. |
π Critical Reminder:
- If the product is a standard paintbrush with a removable handle, it likely falls under9603.40.40.60(Lowest Tax).
- If the product is a plastic applicator tool (no bristles, just a plastic grip/head), it may fall under3926.90.60.90or3926.90.99.89.
- If it is marketed as a general household tool (not strictly for paint application but used for it), it may fall under8205.51.75.00.
- If it is a paint pad or roller mechanism, it falls under9603.90.80.50(Highest Tax).
π° Part 3: 2026 Latest Tariff Rate Breakdown (Including Surtaxes & Policy Add-ons)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Time: 2025/2026 Period (Based on provided data)
π― 1. 9603.40.40.60 ββ Brushes for Applying Paint/Varnish (Best Case Scenario)
| Item | Content |
|---|---|
| Base Duty Rate | 4.0% |
| Section 301 Surtax | 0.0% (Note: Data shows 0.0% for this specific code in the provided list, which is rare for China imports, but we must follow the data) |
| Section 122 Tariff | 10.0% |
| Total Tax Rate | 14.0% |
| Tax Calculation | CIF Value Γ 14.0% |
| De Minimis Exemption | β No (High value threshold usually applies, but explicitly not exempted in context) |
| Legal Basis | Base Tariff 4.0% + Section 122 10% |
π Interpretation:
- This is the most favorable classification if the product is strictly a "paint brush."
- Zero Section 301 tax is a significant advantage, likely due to specific exclusions for certain painting tools.
- The 10% Section 122 tariff is a standard additional duty on Chinese goods.
π― 2. 3926.90.99.89 ββ Other Plastic Articles (Medium Tax)
| Item | Content |
|---|---|
| Base Duty Rate | 5.3% |
| Section 301 Surtax | 7.5% |
| Section 122 Tariff | 10.0% |
| Total Tax Rate | 22.8% |
| Tax Calculation | CIF Value Γ 22.8% |
| De Minimis Exemption | β No |
| Legal Basis | Base Tariff 5.3% + Section 301 7.5% + Section 122 10% |
π Interpretation:
- If customs determines the product is primarily a plastic article (not a bristle brush), the tax jumps to 22.8%.
- This classification assumes the "detachable" feature makes it a general plastic tool rather than a specialized brush.
π― 3. 8205.51.75.00 ββ Household Hand Tools (High Tax)
| Item | Content |
|---|---|
| Base Duty Rate | 3.7% |
| Section 301 Surtax | 25.0% |
| Section 122 Tariff | 10.0% |
| Total Tax Rate | 38.7% |
| Tax Calculation | CIF Value Γ 38.7% |
| De Minimis Exemption | β No |
| Legal Basis | Base Tariff 3.7% + Section 301 25% + Section 122 10% |
π Interpretation:
- If classified as a general hand tool (e.g., a scraper or generic applicator), it incurs the full 25% Section 301 tariff.
- This is significantly more expensive than the dedicated paint brush classification.
π― 4. 3926.90.60.90 ββ Other Plastic Articles (Plastic) (Very High Tax)
| Item | Content |
|---|---|
| Base Duty Rate | 4.2% |
| Section 301 Surtax | 25.0% |
| Section 122 Tariff | 10.0% |
| Total Tax Rate | 39.2% |
| Tax Calculation | CIF Value Γ 39.2% |
| De Minimis Exemption | β No |
| Legal Basis | Base Tariff 4.2% + Section 301 25% + Section 122 10% |
π Interpretation:
- Another plastic classification with the full 25% Section 301 penalty.
- High risk if the product is misclassified as a generic plastic good instead of a specialized tool.
π― 5. 9603.90.80.50 ββ Paint Pads, Rollers, Related Brushes (Highest Tax)
| Item | Content |
|---|---|
| Base Duty Rate | 2.8% |
| Section 301 Surtax | 7.5% |
| Section 122 Tariff | 10.0% |
| Steel/Aluminum/Copper Surcharge | +50% (If applicable components exist) |
| Total Tax Rate | 70.3% (Base + 301 + 122) |
| Tax Calculation | CIF Value Γ 70.3% (+ potentially 50% on metal parts) |
| De Minimis Exemption | β No |
| Legal Basis | Base Tariff 2.8% + Section 301 7.5% + Section 122 10% + Metal Surtax 50% |
π Interpretation:
- Warning: This is the most expensive classification.
- It applies if the product is deemed a paint pad, roller, or industrial brush accessory rather than a standard hand-held paintbrush.
- If the "detachable" part includes steel, aluminum, or copper components, an additional 50% may apply to those parts.
- Avoid this classification unless the product is explicitly a roller/pad system.
π οΈ Part 4: Customs Clearance Practical Advice (Avoid Pitfalls)
β 1. Preparation Checklist (All Documents Required)
| Document | Required? | Explanation |
|---|---|---|
| β Product Specifications | βοΈ | Must detail: Handle material, Bristle type, Detachment mechanism, Intended use (Paint/Varnish). |
| β Product Photos | βοΈ | Clear images of the detached state and assembled state. Label the parts (Handle vs. Head). |
| β Commercial Invoice | βοΈ | Description must be specific: "Detachable Paint Brush with Synthetic Bristles, Plastic Handle." Avoid vague terms like "Tool." |
| β Material Declaration | βοΈ | Explicitly state the percentage of Plastic, Metal, and Bristle materials to avoid misclassification as "Plastic Article" (Ch 39). |
| β Origin Certificate | βοΈ | To prove CN origin and apply correct Section 122/301 rates. |
β 2. Declaration Strategy (Key Mnemonic)
π₯ "Define Function, Not Just Form! 'Paint Brush' = 14%, 'Plastic Tool' = 39%, 'Roller' = 70%!"
| Scenario | Correct HS Code | Tax Rate | Risk Level |
|---|---|---|---|
| Dedicated Paint Brush (Bristles/Synthetic, for paint) | 9603.40.40.60 |
14.0% | β Low (Best Option) |
| Plastic Applicator/Handle (No bristles, general use) | 3926.90.99.89 |
22.8% | β οΈ Medium |
| General Household Tool (Metal/Plastic mix, not specific to paint) | 8205.51.75.00 |
38.7% | π΄ High |
| Generic Plastic Item | 3926.90.60.90 |
39.2% | π΄ High |
| Paint Pad/Roller/Industrial Brush | 9603.90.80.50 |
70.3% | π Extreme (Avoid!) |
β 3. Special Handling Tips
| Situation | Advice |
|---|---|
| Mixed Materials | If the brush has a metal ferrule (the part holding bristles), ensure the declaration emphasizes the bristle function to stay in Ch 96. If the metal part is structural (handle), it might shift to Ch 82. |
| OEM/White Label | Clearly state "Paint Brush" in the description. Do not use generic terms like "Art Supply" or "DIY Tool" without specifying "Paint." |
| Detachable Feature | Explain that the detachability does not change the primary function. It remains a paint brush. The handle is just an accessory. |
| Packaging | If sold separately (Handle sold without head, or Head sold without handle), customs may view them as separate components. Recommendation: Declare as a complete kit. |
π Part 5: Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tax Rate (China Origin) | Certification | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 9603.40.40.60 |
14.0% | None required for basic brushes | Avoid 9603.90.80.50 (70.3%). |
| π¨π³ China | 9603.40.40.60 |
Varies (Export) | CCC (if domestic) | Focus on export compliance. |
| πͺπΊ EU | 9603.30.00 (Approx) |
0-4% | CE (if plastic) | EU tariffs are generally lower; US is the high-tariff market. |
| π¬π§ UK | 9603.30.00 |
4% | UKCA | Post-Brexit rules apply. |
π Conclusion:
- USA is the critical market due to the high variance in tax rates (14% vs 70%).
- Proper Classification is Financially Critical: A misclassification from9603.40.40.60to9603.90.80.50increases tax by 56 percentage points.
π Part 6: Common Mistakes & Pitfalls (Blood & Tears Lessons)
β Mistake 1: Calling it a "Plastic Toy" or "Plastic Tool"
π Consequence: Classified under Ch 39 β 39.2% tax.
π Fix: Always use the word "Brush" and describe the bristle/hair component.
β Mistake 2: Ignoring the "Detachable" aspect
π Consequence: If parts are shipped separately, customs may assign separate HS codes, leading to higher combined duties.
π Fix: Declare as a complete set if shipped together.
β Mistake 3: Classifying as "Paint Roller/Pad" (9603.90.80.50)
π Consequence: 70.3% tax + potential 50% metal surcharge.
π Fix: Ensure the product is a hand-held brush, not a roller or pad applicator.
β Correct Declaration Example:
"Hand-held Paint Brush, Detachable Handle, Synthetic Bristles, Plastic Grip, Model ABC, for Use with House Paint"
π― Part 7: Conclusion: Professional Declaration, Save Costs!
π― Remember the Mnemonic:
πΉ "Brush = 14%, Plastic = 39%, Roller = 70%! Choose Wisely!"
πΉ "Function over Form: Declare 'Paint Brush', not 'Plastic Tool'!"
π Pro Tip:
If your product is shipped from Vietnam or Malaysia, apply for IEEPA Exemption (if applicable) to reduce Section 122/301 tariffs.
Recommend applying for an Advance Ruling (Ruling Letter) from CBP if the product is unique.
π£ Immediate Action:
π Contact a professional Customs Broker + Provide Product Photos + Apply for HS Code Advance Ruling.
π Ensure Smooth Clearance, Maximize Profit, Avoid Surprises!
β¨ Professional Clearance Starts with Accurate Classification!
πΌ Every Dollar Saved is Profit Earned!
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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.