Large Pack Hair Clips
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 7117909000 | 28.5% | CN | US | Official Doc |
| 9615114000 | 15.3% | CN | US | Official Doc |
| 9615903000 | 15.1% | CN | US | Official Doc |
| 3926908500 | 24.0% | CN | US | Official Doc |
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AI Analysis
π Hair Clips & Hair Accessories (Large Pack)
π HS Code Reference & Customs Clearance Guide | 2024/2025 Latest Tariff Analysis | Professional Clearance Strategy
π I. Product Definition and Classification: Do You Really Understand "Hair Clips"?
Hair clips are essential personal care accessories used for styling, securing, or decorating hair. In international trade, they are classified based on material composition and functional characteristics. They generally fall into three main categories:
1. Imitation Jewelry (Metal/Plastic Mix): Often sold in sets, featuring decorative elements that mimic precious metals or stones. 2. Hair Pins/Combs (Plastic/Rubber): Standard functional items made primarily from synthetic materials like plastic or hard rubber. 3. General Plastics: Simple, non-decorative clips classified under general plastic articles if they do not fit specific jewelry or hair accessory subheadings.
β οΈ Key Distinction Point:
- If the item is a decorative set (often with metallic finishes, pearls, or gem-like plastics) β It may be classified as Imitation Jewelry. - If the item is a functional plastic/rubber clip without jewelry characteristics β It is classified under Chapter 96 (Miscellaneous Manufactured Articles). - If the item is a generic plastic clip not specifically described elsewhere β It falls under General Plastic Articles.
π¦ II. HS Code Classification Details (Based on Provided Data)
| HS Code | Product Description | Material/Category | Tax Detail Breakdown |
|---|---|---|---|
7117.90.90.00 |
Hair Clip Sets or Clips, classified as Imitation Jewelry | Metal or Plastic (Decorative) | Base: 11.0% Additional: 7.5% Section 301 (122): 10% Total: 28.5% |
9615.11.40.00 |
Hair Clips, made of Plastic or Hard Rubber | Plastic/Hard Rubber (Functional) | Base: 5.3% Additional: 0.0% Section 301 (122): 10% Total: 15.3% |
9615.90.30.00 |
Hair Clips, Other specific subdivisions | Various (Non-Plastic/Rubber Specific) | Base: 5.1% Additional: 0.0% Section 301 (122): 10% Total: 15.1% |
3926.90.85.00 |
Hair Clips, classified as Plastic Articles | Plastic (General Category) | Base: 6.5% Additional: 7.5% Section 301 (122): 10% Total: 24.0% |
π Key Insight:
- Chapter 71 (Imitation Jewelry) carries the highest duty burden due to higher base rates. - Chapter 96 (Miscellaneous Articles) offers the most competitive rates for standard hair clips. - Section 301 Tariff (122 Clause) applies a flat 10% additional duty to all these codes for Chinese-origin goods.
π° III. 2024/2025 Tariff Rate Detailed Explanation
β Applicable Country: United States (US)
β Origin: China (CN) (Inferred from Section 301 "122 Clause" reference)
β Effective Date: Current tariffs apply as per latest USITC rulings.
π― 1. 7117.90.90.00 β Imitation Jewelry (Hair Clip Sets)
| Item | Content |
|---|---|
| Base Duty | 11.0% |
| Section 301 Additional | 7.5% |
| Section 122 Clause | 10.0% |
| Total Tax Rate | 28.5% |
| Calculation | CIF Value Γ 28.5% |
| De Minimis Eligibility | β No (High value items usually exceed $800 threshold for de minimis, and jewelry often has stricter scrutiny) |
π Explanation:
- This classification assumes the hair clips are marketed as jewelry (e.g., "Sparkly Rhinestone Hair Clips"). - The 11% base duty reflects the higher tariff for imitation jewelry. - Total 28.5% is significantly higher than functional clips. Strategy: Avoid this code unless necessary for branding.
π― 2. 9615.11.40.00 β Plastic/Hard Rubber Hair Clips (Recommended)
| Item | Content |
|---|---|
| Base Duty | 5.3% |
| Section 301 Additional | 0.0% |
| Section 122 Clause | 10.0% |
| Total Tax Rate | 15.3% |
| Calculation | CIF Value Γ 15.3% |
| De Minimis Eligibility | β οΈ Check (If under $800, may qualify under de minimis, but ensure correct classification) |
π Explanation:
- This is the most cost-effective code for standard plastic hair clips. - The 5.3% base duty is low for plastic accessories. - No Section 301 Additional Duty (only the 122 Clause applies), making it 13.2% cheaper than the jewelry classification.
π― 3. 9615.90.30.00 β Other Hair Clips
| Item | Content |
|---|---|
| Base Duty | 5.1% |
| Section 301 Additional | 0.0% |
| Section 122 Clause | 10.0% |
| Total Tax Rate | 15.1% |
| Calculation | CIF Value Γ 15.1% |
| De Minimis Eligibility | β οΈ Check |
π Explanation:
- Use this for hair clips that donβt fit the specific "plastic/hard rubber" description (e.g., mixed materials, metal cores with plastic coating not classified as jewelry). - Lowest total rate (15.1%) among all options. Best for mixed-material functional clips.
π― 4. 3926.90.85.00 β General Plastic Articles
| Item | Content |
|---|---|
| Base Duty | 6.5% |
| Section 301 Additional | 7.5% |
| Section 122 Clause | 10.0% |
| Total Tax Rate | 24.0% |
| Calculation | CIF Value Γ 24.0% |
| De Minimis Eligibility | β οΈ Check |
π Explanation:
- This is a "catch-all" for plastic items not specifically described elsewhere. - While it avoids the high jewelry duties, the 7.5% Section 301 additional duty makes it more expensive than the Chapter 96 options. - Use only if Chapter 96 codes are explicitly incorrect.
π οΈ IV. Customs Clearance Practical Advice (Real-World Pitfall Avoidance)
β 1. Documentation Checklist (Non-Negotiable)
| Document | Required? | Description |
|---|---|---|
| β Product Catalogue | βοΈ | Clear photos showing material (plastic vs. metal/jewelry-like) |
| β Material Declaration | βοΈ | Explicitly state "100% Plastic" or "Plastic with Metal Clasp" |
| β Commercial Invoice | βοΈ | Describe as "Plastic Hair Clips" or "Hair Accessories," NOT "Jewelry" |
| β Packing List | βοΈ | Indicate "Large Pack" contents to avoid quantity discrepancies |
| β Country of Origin | βοΈ | Must state "Made in China" to apply correct Section 122 rates |
β 2. Declaration Tips (Critical Keywords)
π₯ "Don't Call It Jewelry, Call It Accessory!"
| Scenario | Correct Declaration | Incorrect Declaration |
|---|---|---|
| Plastic Bobby Pins | 9615.11.40.00 β "Plastic Hair Clips" |
"Hair Jewelry" β 7117.90.90.00 (28.5%) |
| Mixed Material Clips | 9615.90.30.00 β "Hair Accessories, Mixed Material" |
"Costume Jewelry" β 7117.90.90.00 |
| Generic Plastic Clips | 3926.90.85.00 β "Plastic Articles" |
"Hair Pins" (if incorrectly interpreted) |
| Set of 12 Clips | Single HS Code for the set | Declaring each clip separately β Higher admin cost |
β 3. Special Handling for "Large Pack" Items
| Situation | Advice |
|---|---|
| Bulk Packaging | Ensure the invoice lists the total quantity and unit price. If the pack is sold as a single SKU, declare one line item. |
| Mixed Materials | If a pack contains both plastic clips and metal claws, declare the principal material or the primary function. If decorative, risk higher duty. |
| Gift Sets | If sold as a gift set with other items (e.g., clips + brush), declare as a set under the essential character item. |
π V. Global Market Comparison (2024/2025)
| Country/Region | Recommended HS Code | Estimated Duty (China Origin) | Notes |
|---|---|---|---|
| πΊπΈ USA | 9615.11.40.00 |
15.3% | Best for plastic clips. Avoid jewelry classification. |
| πͺπΊ EU | 9615.11.00 |
~4.7% | No Section 301 equivalent. Lower base duty. |
| π¨π³ China | 9615.11.00 |
5.3% | Import duty for domestic resale. |
| π¬π§ UK | 9615.11.00 |
~4.7% | Post-Brexit tariffs similar to EU. |
π Conclusion:
- The USA has the highest effective duty for Chinese-made hair clips due to Section 301/122 Clauses. - Chapter 96 is the safest and cheapest path for plastic hair clips. - Avoid Chapter 71 unless your product is genuinely marketed as "Jewelry" and you accept the 28.5% tax.
π VI. Common Mistakes & Pitfalls (Lessons Learned)
β Mistake 1: Declaring plastic hair clips as "Imitation Jewelry"
π Result: Pay 28.5% instead of 15.3%. Loss of Profit!
β Mistake 2: Using 3926.90.85.00 for plastic hair clips
π Result: Pay 24.0% due to Section 301 additional duty. Inefficient!
β Mistake 3: Not declaring "Made in China" correctly
π Result: May face Section 122 10% Clause unexpectedly if origin is disputed.
β Mistake 4: Packing "Large Pack" as multiple small shipments to exploit de minimis
π Result: CBP may aggregate shipments and deny de minimis exemption if deemed "split shipments."
β Correct Practice:
"Plastic Hair Clips, 12pc/Set, Model HC-2024, Made in China, HS Code: 9615.11.40.00"
π― VII. Conclusion: Smart Classification, Higher Margins
π― Remember the Rule:
πΉ "Plastic & Functional = Chapter 96 (15% Tax)"
πΉ "Decorative & Jewelry-Like = Chapter 71 (28.5% Tax)"
πΉ "Generic Plastic = Chapter 39 (24% Tax)"
π Pro Tip:
- If your hair clips are purely plastic and functional, always use 9615.11.40.00 or 9615.90.30.00.
- Provide clear product images to customs brokers to prove they are not imitation jewelry.
- Always apply for Section 301 Exclusions if applicable (though rare for hair clips), and ensure Section 122 is correctly applied.
π£ Immediate Action:
π Confirm Material: Is it 100% plastic? β Use
9615.11.40.00
π Check Design: Is it decorative/metallic? β Use7117.90.90.00(Prepare for 28.5%)
π Document Clearly: "Hair Accessories" not "Jewelry" on Invoice.
β¨ Precision in Classification = Precision in Profit!
πΌ Every 1% Tax Saving Adds to Your Bottom Line!
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.