Dry Shampoo
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3305100000 | 35.0% | CN | US | Official Doc |
| 3305900000 | 35.0% | CN | US | Official Doc |
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AI Analysis
πΏ Dry Shampoo (Hair Preparations)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Customs Strategy
π I. Product Definition & Classification: Do You Really Understand "Dry Shampoo"?
Dry shampoo is a cosmetic preparation designed to absorb oil and grease from the hair without water. It typically comes in powder form or as an aerosol spray. In international trade, it is strictly classified under Chapter 33 (Essential Oils and Resinoids; Perfumery, Cosmetics and Toilet Preparations).
The classification depends primarily on its form and primary function:
- Shampoos (Aerosol/Spray Powder): Even though it doesn't contain water for rinsing, if it is marketed and used as a shampoo substitute (cleansing/preparation for use on hair), it falls under the specific subheading for "Shampoos."
- Other Hair Preparations: If the product is primarily for styling, conditioning, or texturizing without being explicitly marketed as a "shampoo" substitute, it falls under "Other preparations for use on the hair."
β οΈ Key Distinction Point:
- If the product label says "Dry Shampoo," "Hair Powder," or "Waterless Shampoo" β HS Code 3305.10.00.00
- If the product is a styling spray, heat protectant, or hair powder NOT marketed as a shampoo β HS Code 3305.90.00.00
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Applicable Scenario | Tax Rate (US/China Origin) |
|---|---|---|---|
3305.10.00.00 |
Preparations for use on the hair: Shampoos | Dry shampoos, aerosol hair powders marketed as cleansing agents | 25.0% |
3305.90.00.00 |
Preparations for use on the hair: Other | Hair sprays, gels, styling creams, hair powders not classified as shampoos | 25.0% |
π Key Reminder:
- Both categories fall under Chapter 33, which generally carries low base tariffs but is subject to Section 301 Additional Duties for products originating in China. - Do not misclassify as "Perfumes" (3303) or "Cosmetics" (3304). Hair-specific preparations have their own dedicated subheading (3305).
π° III. 2026 Latest Tariff Rate Breakdown (Including Surtax & Policy Add-ons)
β Applicable Country: United States (US)
β Country of Origin: China (CN)
β Effective Date: November 10, 2025 (including subsequent imports)
π― 1. 3305.10.00.00 β Preparations for use on the hair: Shampoos (Includes Dry Shampoo)
| Item | Content |
|---|---|
| Base Tariff Rate | 0% (ad valorem) |
| USITC Additional Tariff | +25% (Under USITC Footnote 9903.88.01) |
| IEEPA Additional Tariff | +0% (Note: Section 301 applies fully) |
| Total Tax Rate | 25.0% |
| Tax Calculation | CIF Value Γ 25% |
| De Minimis Eligibility | β No (deny_de_minimis) |
| Legal Basis Path | USITC:3305.10.00.00 β FOOTNOTE:9903.88.01 |
π Explanation:
- The 25% additional duty is imposed under Section 301 of the Trade Act of 1974 against Chinese goods. - Although the base MFN (Most Favored Nation) rate for hair shampoos is 0%, the 25% surtax makes the total effective rate 25%. - This applies to all Chinese-origin dry shampoos imported into the US.
π― 2. 3305.90.00.00 β Preparations for use on the hair: Other
| Item | Content |
|---|---|
| Base Tariff Rate | 0% (ad valorem) |
| USITC Additional Tariff | +25% (Under USITC Footnote 9903.88.01) |
| IEEPA Additional Tariff | +0% |
| Total Tax Rate | 25.0% |
| Tax Calculation | CIF Value Γ 25% |
| De Minimis Eligibility | β No |
| Legal Basis Path | USITC:3305.90.00.00 β FOOTNOTE:9903.88.01 |
π Note:
- Even if the product is not a shampoo (e.g., hair powder, styling spray), it still falls under 3305.90. - The 25% surtax remains the same. There is no tariff advantage for classifying as "Other" vs. "Shampoo" for Chinese goods.
π οΈ IV. Customs Clearance Practical Advice (Combat Pitfalls)
β 1. Required Documentation Checklist (Must-Have)
| Document | Must Provide | Notes |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must state ingredients, net weight, and usage instructions. |
| β Ingredients List (INCI) | βοΈ | Required for cosmetic compliance; helps customs verify itβs not a chemical product. |
| β Product Photos (Label & Package) | βοΈ | Must show "Dry Shampoo," brand, and manufacturing origin ("Made in China"). |
| β Commercial Invoice | βοΈ | Clearly state: "Dry Shampoo for Hair Use" β Do not use vague terms like "Cosmetic" |
| β FDA Registration (if applicable) | βοΈ | While FDA does not pre-approve cosmetics, facilities must be registered. |
| β Certificate of Origin (CO) | βοΈ | To prove Chinese origin (triggers 25% tariff). |
| β Packing List | βοΈ | Show gross/net weight accurately. |
β 2. Declaration Tips (Key Mnemonics)
π₯ "Be Specific: 'Dry Shampoo' Not 'Cosmetic'!"
| Scenario | Correct Declaration | Incorrect Practice |
|---|---|---|
| Dry Shampoo (Aerosol/Powder) | 3305.10.00.00 - Dry Shampoo |
Misdeclare as "Perfume" (3303) β Risk of rejection |
| Hair Spray (Styling) | 3305.90.00.00 - Hair Preparation |
Misdeclare as "Cosmetic" (3304) β Classification error |
| Bulk Powder (Not for Direct Use) | May fall under 3305.90.00.00 or chemical chapter |
Do not declare as "Finished Cosmetic" |
| Travel-Size Kits | Same HS Code, but check FDA labeling rules | Do not split package parts |
β 3. Special Case Handling
| Situation | Handling Advice |
|---|---|
| Aerosol vs. Powder | Both are 3305.10.00.00. Aerosols may require additional DOT (Department of Transportation) compliance for shipping, but HS remains the same. |
| "Non-Chinese" Origin | If manufactured in Thailand, Vietnam, or Mexico, you may apply for preferential tariffs or avoid Section 301 duties. Provide Certificate of Origin from non-China country. |
| OEM/White Label | Ensure the manufacturer on the label matches the Country of Origin document. |
| FDA Compliance | Cosmetics must comply with FDA labeling requirements (ingredient list, net weight, business address). Non-compliance can lead to detention at customs. |
π V. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Certification Requirement | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 3305.10.00.00 |
25.0% (Section 301) | FDA Registration + Labeling | High tariff; ensure accurate description |
| π¨π³ China | 3305.10.00.00 |
5% | Cosmetics Notification | No surtax |
| πͺπΊ EU | 3305.10.00.00 |
0% (Most Cases) | CPNP Notification + VPA | No Section 301 tax |
| π¬π§ UK | 3305.10.00.00 |
0% | UKCPNP Notification | Post-Brexit rules apply |
| π¦πΊ Australia | 3305.10.00.00 |
5% | TGA Listing (if therapeutic) | Standard cosmetics tax |
| π―π΅ Japan | 3305.10.00.00 |
0% | Japan Cosmetic Notification | Low base tariff |
π Conclusion:
- USA is the only major market imposing a 25% additional tariff on Chinese dry shampoos under Section 301.
- EU, UK, Japan, and Australia offer 0-5% tariffs, making them more cost-effective for Chinese manufacturers.
- Consider diversifying supply chains to non-China countries to avoid US tariffs.
π VI. Common Errors & Pitfalls (Lessons Learned)
β Error 1: Declaring "Dry Shampoo" as "Perfume" (3303)
π Consequence: Customs will reclassify and apply penalties. Perfume duties may differ.
β Error 2: Using vague description "Cosmetic Powder"
π Consequence: Customs may delay shipment for classification review. Be specific!
β Error 3: Ignoring Section 301 Surtax
π Consequence: Underpaying duties leads to back taxes + interest + fines.
β Error 4: Failing to Provide Ingredients List
π Consequence: FDA may detain the shipment for non-compliance with labeling laws.
β Correct Practice:
"Dry Shampoo, Aerosol, 150ml, Contains Ethanol & Starch, For Hair Cleansing, Made in China, Model XYZ"
π― VII. Conclusion: Professional Declaration, Save Costs & Time!
π― Remember Mnemonic:
πΉ "Dry Shampoo = 3305.10, Other Hair = 3305.90, Both 25% for China!"
πΉ "HS Code Determines Tax, 25% Surcharge is Real, Declare Accurately, Avoid Delays!"
π Pro Tip:
If your dry shampoo is manufactured in Thailand, Vietnam, or Mexico, you can apply for non-China origin rules to avoid the 25% Section 301 tariff.
Consider applying for an Advance Ruling from US Customs if you have unique formulations or mixed-origin products.
π£ Immediate Action:
π Contact a Licensed Customs Broker + Provide Product Label + Verify Ingredients List
π Ensure smooth clearance, avoid penalties, and maximize profits!
β¨ Professional Customs Clearance Starts with Accurate Classification!
πΌ Every Dollar Saved is a Dollar 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.