Eyelash Comb

👁️ Eyelash Comb (False Eyelash Applicator)

🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional-Level Clearance Strategy
📌 Part I: Product Definition & Classification: Do You Really Understand the "Eyelash Comb"?

The "Eyelash Comb" (often sold as an eyelash brush, separator, or false lash applicator) is a cosmetic tool used to separate, curl, or apply false eyelashes. In international trade, its classification depends heavily on material, function, and whether it is considered a cosmetic container or a simple brush/tool.

Based on the provided data, there are 5 potential HS Code classifications, ranging from specific cosmetic brushes to general household tools. The choice of HS code drastically affects the total tax burden due to current US trade policies (Section 301 & IEEPA).

⚠️ Key Distinction Point:
- If classified as a Cosmetic Brush (Section 96) → Low Base Tariff (0.2¢ or 2.6%)
- If classified as a Cosmetic Product/Preparation (Section 33) → High Base Tariff (0%) + Heavy Surcharges
- If classified as a Household Comb (Section 96) → Medium Base Tariff (5.3%)

📦 Part II: HS Code Classification Details (2026 Latest Tariff Authority Comparison)

🔍 Critical Note:
- Most Favorable: 9603.29.40.10 (17.2%) or 9615.11.40.00 (15.3%)
- Least Favorable: 3304.20.00.00 or 3304.99.50.00 (35.0%)
- Misclassification Risk: Classifying a plastic tool as a "cosmetic preparation" (3304) leads to significantly higher taxes due to the 25% Section 301 tariff being applied on top of the IEEPA tariff.

💰 Part III: 2026 Latest Tariff Rate Breakdown (Including Surcharges & Policy Add-ons)

✅ Applicable Country: United States (US)
✅ Country of Origin: China (CN)
✅ Effective Time: Post-2025 (Current Trade Environment)

🎯 1. 9603.29.40.10 —— Eyelash Brushes (Most Accurate Match)

📌 Explanation:
- This is the most precise classification for eyelash brushes.
- The base tariff includes a small per-unit fee (0.2¢) plus 7%.
- The 10% IEEPA tariff applies.
- Total Cost Impact: Moderate. Highly recommended for accurate classification.

🎯 2. 9603.30.20.00 —— Other Makeup Brushes

📌 Note:
- Slightly higher than 9603.29.40.10 due to the 7.5% Section 301 surcharge.
- Still within the "Brush" category (Chapter 96), which is generally more favorable than Chapter 33.

🎯 3. 3304.20.00.00 & 3304.99.50.00 —— Eye Makeup / Other Beauty Preparations

📌 Warning:
- Although the base tariff is 0%, the 25% Section 301 tariff is applied because these goods are categorized under "Beauty Preparations" (Chapter 33) from China.
- Total Tax is 35%, which is double the cost of classifying it as a brush (9603).
- Do NOT use this classification for a plastic/metal comb unless it is a cosmetic cream/powder container.

🎯 4. 9615.11.40.00 —— Combs (Plastic or Hard Rubber)

📌 Note:
- This is the lowest total tax rate (15.3%) if the product can be reasonably described as a "comb" made of plastic/hard rubber.
- However, customs may argue that an "eyelash comb" is not a standard "comb" (Chapter 96.15) but a cosmetic tool (Chapter 96.03).
- Risk: Higher scrutiny from customs due to functional ambiguity.

🛠️ Part IV: Customs Clearance Practical Advice (Avoiding Pitfalls)

✅ 1. Recommended HS Code Strategy

🔥 Golden Rule:
"Classify as Brush (9603), Not Preparation (3304)! Save 18% Tax!"

✅ 2. Declaration Tips (Key Keywords)

📌 Documentation Requirements:
- Product Photos: Clear images showing bristles/handles.
- Material Declaration: Specify "Plastic" or "Metal" and "Nylon/Bristles".
- Usage Statement: Explicitly state "For separating or applying false eyelashes," not "Applying makeup."

✅ 3. Special Cases

🌍 Part V: Global Market Comparison (2026)

📌 Conclusion:
- USA has the highest barrier due to Section 301 and IEEPA tariffs.
- Correct classification (9603 vs 3304) is the single biggest factor in cost control.

📌 Part VI: Common Errors & Pitfalls (Blood Tears Lessons)

❌ Error 1: Declaring Eyelash Comb as 3304.99.50.00 (Beauty Prep)
👉 Consequence: Tax jumps from 17.2% to 35.0%.
👉 Reason: Customs sees "Beauty Tool" and incorrectly assigns it to Chapter 33.

❌ Error 2: Ignoring the "Per Unit" Fee in 9603.29.40.10
👉 Consequence: Underpayment for high-volume shipments.
👉 Note: 0.2¢ per unit adds up quickly (e.g., 100,000 units = $200 extra).

❌ Error 3: Using 9615 for complex brush-tools
👉 Consequence: Customs may reject "Comb" classification if the item has bristles/brushes.
👉 Fix: Use 9603 (Brushes) if bristles are present.

✅ Correct Action:

"Eyelash Brush, Plastic Handle, Synthetic Bristles, for Cosmetic Application, HS 9603.29.40.10"

🎯 Part VII: Conclusion: Professional Declaration, Cost Saving!

🎯 Remember the Golden Rule:

🔹 "Brush = 9603, Prep = 3304"
🔹 "3304 = 35% Tax (Expensive!)"
🔹 "9603 = ~17% Tax (Cheaper!)"
🔹 "9615 = 15.3% Tax (Risky but Cheap)"

📌 Pro Tip:
If your eyelash comb is exported to Vietnam, Mexico, or Thailand first, you might qualify for IEEPA Exemptions, reducing taxes to 0%~5%.
Consider Advance Ruling with US Customs (CBP) to lock in the 9603 classification.

📣 Immediate Action:

📞 Contact your customs broker with photos!
🚀 Declare as 9603.29.40.10 to save 18% tax!

✨ Precision Classification, Maximum Profit!
💼 Your Duty Cost Should Be Calculated, Not Guessed!