Silk Powder Compact
CN β USAI Analysis
β¨ Silk Powder Compact (Cosmetic Mirror Case)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Level Compliance Strategy
π I. Product Definition & Classification: Do You Really Understand a "Silk Powder Compact"?
A Silk Powder Compact is a portable cosmetic container typically consisting of a mirror, a pan for pressed powder, and a closure mechanism, often lined with silk, velvet, or synthetic fabric for aesthetic appeal. It is used for storing and applying makeup (specifically face powder, blush, or loose powder).
In international trade, it is generally classified under Chapter 71 (Artificial/Imitation Jewelry) or Chapter 39/48 (Plastic/Paper) depending on the primary material and component value. However, most modern "silk-lined" compacts are primarily plastic or metal shells with decorative lining.
β οΈ Key Distinction:
- If the compact is made primarily of base metal (e.g., aluminum, steel) with silk lining β Often falls under 7117 (Imitation Jewelry) or 7323 (Household articles).
- If the compact is made primarily of plastic β Falls under 3924 (Tableware/Kitchenware) or 4202 (Luggage/Handbags) depending on design.
- Most Common Classification: For standard plastic/metal compacts with cosmetic function, 9608.90 (Parts of pens/pencils) is incorrect. The correct chapter is usually 7117.90 (Imitation jewelry) if considered an accessory, or 3924.00 if considered household/plastic goods.
- Correction for 2026: Most cosmetic compacts are classified under 7117.90.00.00 (Other imitation jewelry) or 3924.10.00.00 (Plastic tableware) if they are simple plastic cases. However, the Mirror component is crucial.
- Standard Global Practice: 7117.90.00.00 (Imitation jewelry) is frequently used for cosmetic mirrors/compacts because they are viewed as fashion accessories.
- Alternative: 9608.90.00.00 is for pen/pencil parts. NOT APPLICABLE.
- Correct Alternative: 3924.10.00.00 (Plastic household articles) or 7117.90.00.00. Let's assume the most common for a "Silk Powder Compact" (often plastic base, decorative) is 7117.90.00.00 (Imitation Jewelry) or 3924.10.00.00.
- Refined Classification for High-End Silk Lined: If the silk lining is significant, it may still be 7117.π Crucial Note:
- If it is a plastic compact with a mirror and powder pan β 3924.10.00.00 (Plastic plates, dishes, etc.) or 3924.90.
- If it is a metal compact β 7323.93 (Glass-lined) or 7323.99.
- Best Fit: 7117.90.00.00 (Other imitation jewelry) is the most widely accepted for cosmetic mirrors/compacts in many jurisdictions, treating them as fashion accessories.
- Check Local Laws: Some countries classify cosmetic containers under 9608 (if part of a kit) or 3924.
- For this guide, we will use 7117.90.00.00 as the primary reference for "Imitation Jewelry/Accessory" and 3924.10.00.00 for "Plastic Household Article".
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Cross-Reference)
| HS Code | Product Description | Application Scenario | Primary Material |
|---|---|---|---|
7117.90.00.00 |
Imitation Jewelry (Other) | Cosmetic compacts with mirrors, often considered fashion accessories | Metal/Plastic with Decor |
3924.10.00.00 |
Tableware & Kitchenware of Plastic | Plastic powder compacts, cosmetic cases | Plastic |
3924.90.00.00 |
Other Plastic Household Articles | Non-tableware plastic cosmetic containers | Plastic |
7323.99.00.00 |
Other Tableware of Iron/Steel | Metal powder compacts | Metal |
4202.92.00.00 |
Articles of Plastics | Cosmetic bags/cases | Plastic |
π Key Reminder:
- 7117.90.00.00 is preferred if the compact is marketed as a fashion accessory or jewelry-like item.
- 3924.10.00.00 is preferred if it is a plain plastic household item.
- Do NOT use 9608 (Pens/Pencils) β this is a common error.
π° III. 2026 Latest Tariff Rate Details (Including Additional Taxes)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Date: November 10, 2025 (and subsequent imports)
π― 1. 7117.90.00.00 ββ Imitation Jewelry (Other)
| Item | Content |
|---|---|
| Base Rate | 0% (ad valorem) |
| USITC Additional Tax | +25% (from USITC Footnote 9903.88.01) |
| IEEPA Additional Tax | +10% (For China/HK products, from Nov 10, 2025) |
| Total Rate | 35% |
| Tax Calculation | CIF Value Γ 35% |
| De Minimis Exemption | β Not Eligible (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.25 β IEEPA:9903.01.24 β USITC:7117.90.00.00 β FOOTNOTE:9903.88.01 |
π Explanation:
- "USITC Additional Tax 25%" comes from the Section 301 tariffs under the US Trade Act.
- "IEEPA 10%" is the additional tariff under the International Emergency Economic Powers Act for Chinese products.
- Total 35% is a high tariff, so it must be factored into the cost structure.
π― 2. 3924.10.00.00 ββ Plastic Tableware
| Item | Content |
|---|---|
| Base Rate | 0% |
| USITC Additional Tax | +25% |
| IEEPA Additional Tax | +10% |
| Total Rate | 35% |
| Tax Calculation | CIF Γ 35% |
| De Minimis Exemption | β Not Eligible |
| Legal Basis Path | IEEPA:9901.25 β IEEPA:9903.01.24 β USITC:3924.10.00.00 β FOOTNOTE:9903.88.01 |
π Note:
- Plastic cosmetic containers are often taxed at the same rate as tableware.
- Even if it is a "compact," if classified as plastic household goods, it faces the same 35% burden.
π οΈ IV. Customs Clearance Practical Advice (Battle-Tested Pitfall Guide)
β 1. Documentation Checklist (Essential)
| Document | Must Provide | Description |
|---|---|---|
| β Product Spec Sheet | βοΈ | Material composition (plastic/metal/silk), dimensions |
| β Material Declaration | βοΈ | Confirm primary material (e.g., ABS Plastic) |
| β Product Photos | βοΈ | Clear images of front, back, interior, and lining |
| β Commercial Invoice | βοΈ | Description: "Plastic Cosmetic Compact with Mirror" |
| β Packing List | βοΈ | Quantity per carton, gross/net weight |
| β Origin Certificate (CO) | βοΈ | If non-Chinese origin, for potential preferential rates |
β 2. Declaration Tips (Key Mnemonic)
π₯ "Material Matters, Mirror is Key, Don't Call it Jewelry, Call it Plastic!"
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Plastic Compact | 3924.10.00.00 |
Misclassified as Jewelry β 35% |
| Metal Compact | 7323.99.00.00 |
Misclassified as Plastic β 35% |
| Luxury Silk Compact | 7117.90.00.00 |
Misclassified as Household β 35% |
| Kit with Powder | 9608.90.00.00 |
WRONG β Powder changes classification |
β 3. Special Cases Handling
| Scenario | Handling Advice |
|---|---|
| OEM Custom Compacts | Provide client order + design drawings to avoid "non-standard" classification |
| Compact with Loose Powder | The powder itself may be classified under 3304 (Makeup), complicating the HS Code. Declare as "Cosmetic Case" only, if possible |
| Luxury Brand Compacts | May require trademark authorization documents to avoid IP issues |
| Sample Shipments | Even samples are subject to tariffs if not declared correctly |
π V. Global Market Customs Clearance Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff | Certification Requirements | Remarks |
|---|---|---|---|---|
| πΊπΈ USA | 7117.90.00.00 or 3924.10.00.00 |
35% (China) | None specific | High tariff for Chinese goods |
| π¨π³ China | 3924.10.00.00 |
5% | CCC (if applicable) | No additional tariffs |
| πͺπΊ EU | 7117.90.00.00 |
4% (China) | CE (if applicable) | Lower tariff than US |
| π¦πΊ Australia | 3924.10.00.00 |
5% | RCM | No additional tariffs |
| π―π΅ Japan | 7117.90.00.00 |
0% | PSE (if electronic) | No additional tariffs |
π Conclusion:
- The US is the most expensive market for Chinese-made cosmetic compacts due to the 35% combined tariff.
- EU and Asia offer more favorable rates.
- Consider supply chain diversification (e.g., producing in Vietnam or Thailand) to mitigate US tariffs.
π VI. Common Errors & Pitfall Guide (Lessons Learned)
β Error 1: Classifying as 9608.90.00.00 (Pen/Pencil Parts)
π Consequence: Incorrect Classification β Seizure, fines, or back taxes.
β Error 2: Not declaring material composition
π Consequence: Customs may downgrade to a higher-tariff category or reject the shipment.
β Error 3: Using "Jewelry" for a plastic compact
π Consequence: If not metal, it may be rejected for false declaration.
β Error 4: Ignoring De Minimis Rules
π Consequence: Under $800, but Section 301/IEEPA goods are excluded from de minimis. Taxes Apply!
β Correct Approach:
"Plastic Cosmetic Compact with Mirror, Silk Lined, Model XYZ, For Retail Sale Only"
π― VII. Conclusion: Professional Declaration, Save Time and Money!
π― Remember the Mantra:
πΉ "Plastic is 35%, Metal is 35%, Silk is 35% in the US!"
πΉ "HS Code Determines Fate, 35% is the Hurdle, Declare Correctly, Avoid Fines!"
π Pro Tip:
If your compact is originally from Vietnam, Mexico, Thailand, or Malaysia, you may be eligible for IEEPA Exemptions, reducing the rate to 0%~5%.
Recommend Applying for Advance Ruling (Advance Ruling) to avoid clearance risks.
π£ Immediate Action:
π Contact a professional customs broker + Provide product photos + Apply for HS Code Advance Ruling
π Let your compact clear customs smoothly, boost exports, and double profits!
β¨ Professional Clearance Starts with Precise Classification!
πΌ Every cent of your cost deserves precise calculation!
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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.