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CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 7113195091 | 23.0% | CN | US | Official Doc |
| 7117909000 | 28.5% | CN | US | Official Doc |
| 7113195095 | 23.0% | CN | US | Official Doc |
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AI Analysis
📌 Brooches (Hair Clips & Brooches)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
📌 1. Product Definition & Classification: Do You Really Understand "Brooches"?
Brooches, including those used as hair clips, fall under the category of Jewelry and Imitation Jewelry. In international trade, their classification depends heavily on the material composition (precious metal vs. base metal) and the nature of the article (real jewelry vs. imitation/fashion accessory).
Key Distinction Points:
- If made of Gold/Silver/Precious Metals (or clad in them) → Classified under Chapter 71 (Head 7113).
- If made of Base Metals, Plastic, Glass, etc. → Classified under Imitation Jewelry (Head 7117).
⚠️ Critical Note:
- "Hair Clip Brooches" are functionally jewelry. Even if used to hold hair, if they are decorative, they are classified as brooches/jewelry, not simple hardware.
- Material is the primary driver for HS Code selection here.
📦 2. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
Based on the provided data, here are the three most likely HS Codes for Brooches, depending on material and structure:
| HS Code | Product Description | Material/Attribute | Tax Detail Breakdown | Total Tax Rate |
|---|---|---|---|---|
7113.19.50.91 |
Gold Jewelry Articles (Non-chain) (e.g., Gold Brooches) |
Gold / Precious Metal Specifically non-chain gold jewelry items. |
Base Duty: 5.5% Additional Duty: 7.5% Section 301 (122) |
23.0% |
7113.19.50.95 |
Other Precious Metal Jewelry (e.g., Silver, Platinum, or Gold-clad) |
Precious Metal or Clad Precious Metal General "other" category for precious metal jewelry not specifically gold. |
Base Duty: 5.5% Additional Duty: 7.5% Section 301 (122) |
23.0% |
7117.90.90.00 |
Imitation Jewelry (Fashion Brooches/Hair Clips) |
Base Metal / Non-Precious Materials Items made of copper, brass, plastic, etc., intended as fashion accessories. |
Base Duty: 11.0% Additional Duty: 7.5% Section 301 (122) |
28.5% |
🔍 Key Insight:
- Real Jewelry (7113) incurs a lower base duty (5.5%) but is still subject to additional tariffs.
- Imitation Jewelry (7117) incurs a higher base duty (11.0%) due to the "Section 301" and base rate combination, resulting in a higher total tax (28.5%).
- The "122 Clause" (Section 301 Tariffs) adds 10% in all cases, significantly impacting the final cost.
💰 3. 2026 Latest Tariff Rate Explanation (Detailed Breakdown)
✅ Applicable Country: United States (US)
✅ Origin: China (CN)
✅ Effective Date: Current tariffs apply as per Section 301 regulations.
🎯 1. 7113.19.50.91 & 7113.19.50.95 —— Precious Metal Jewelry (Brooches)
| Item | Content |
|---|---|
| Base Tariff Rate | 5.5% (Ad Valorem) |
| Section 301 Additional Tariff (122 Clause) | +10% (Specific to Chinese origin goods under current trade policy) |
| Other Additional Duties | +7.5% (This likely refers to specific antidumping/countervailing duties or other statutory add-ons depending on the specific tariff schedule version, but as per data, it is a fixed component) |
| Total Tax Rate | 23.0% |
| Calculation Basis | CIF Value × 23.0% |
| De Minimis Exemption? | ❌ NO Jewelry items are generally not eligible for de minimis (Section 321) exemption if valued above thresholds or if subject to specific trade remedies. Check latest CBP rulings. |
📌 Explanation:
- The 5.5% is the standard Most Favored Nation (MFN) rate for jewelry.
- The 10% is the Section 301 tariff explicitly listed in the data as "122 Clause."
- The 7.5% appears to be an additional statutory duty or a specific rate component included in the total.
- Total: 5.5 + 7.5 + 10 = 23.0%.
🎯 2. 7117.90.90.00 —— Imitation Jewelry (Fashion Brooches/Hair Clips)
| Item | Content |
|---|---|
| Base Tariff Rate | 11.0% (Ad Valorem) |
| Section 301 Additional Tariff (122 Clause) | +10% |
| Other Additional Duties | +7.5% |
| Total Tax Rate | 28.5% |
| Calculation Basis | CIF Value × 28.5% |
| De Minimis Exemption? | ❌ NO Imitation jewelry from China is subject to the same trade restrictions as precious jewelry regarding Section 301. |
📌 Explanation:
- The 11.0% base rate is higher than for precious metals, reflecting the lower value-add nature of imitation goods.
- Combined with the 10% Section 301 and 7.5% other duties, the total burden is 5.5 percentage points higher than for precious metal jewelry.
- Total: 11.0 + 7.5 + 10 = 28.5%.
🛠️ 4. Customs Clearance Practical Advice (Pitfall Avoidance Guide)
✅ 1. Required Documentation Checklist (All or Nothing)
| Document | Mandatory | Description |
|---|---|---|
| ✅ Product Composition Statement | ✔️ | Must clearly state material: "14k Gold," "Stainless Steel," "Zinc Alloy," etc. Crucial for distinguishing 7113 vs 7117. |
| ✅ Commercial Invoice | ✔️ | Must describe item as "Brooch" or "Hair Ornament," not just "Accessories." |
| ✅ Material Certificate | ✔️ | For precious metals (7113), proof of gold/silver content may be requested to verify duty rate. |
| ✅ Photos of Product | ✔️ | Show details to confirm it is a decorative brooch, not a functional metal clip (which might be HTS 7320). |
| ✅ Packing List | ✔️ | Ensure weight and quantity match invoice. |
✅ 2. Declaration Strategy (Key Tips)
🔥 “Material Defines Code, Don’t Guess, Confirm!”
| Scenario | Correct HS Code | Risk of Error |
|---|---|---|
| Gold/Silver Brooch | 7113.19.50.91 or 7113.19.50.95 |
Low Risk if material is certified. High Risk if mislabeled as "base metal." |
| Fashion Brooch (Plastic/Metal) | 7117.90.90.00 |
Medium Risk. If customs tests and finds precious metal content, they may reclassify to 7113 and assess penalties. |
| Purely Functional Metal Hair Clip | Not Listed (Likely 7320.90 or 8305) |
High Risk. If declared as jewelry but is purely functional (e.g., a plain steel barrette), it may be reclassified, leading to duty differences and delays. |
📌 Important:
- Do not declare all brooches as "Imitation Jewelry" to save time if they are actually precious metal. This is fraud.
- Do not declare base metal brooches as "Gold" to try to claim lower base rates (5.5% vs 11.0%) if they are not actually gold. The 10% Section 301 applies to both, so the savings are minimal (5.5% vs 11% base), but the risk of seizure and fines is huge.
✅ 3. Special Cases & Recommendations
| Case | Handling Advice |
|---|---|
| Mixed Materials (e.g., Gold-plated Base Metal) |
Generally classified under 7113 if the precious metal is the primary surface material. Provide plating thickness details. |
| Set Jewelry (Brooch with attached chain) |
If the chain is integral, it may still fall under 7113. If detachable, ensure description reflects the primary item (brooch). |
| Custom Design (Artisanal Pieces) |
Provide detailed descriptions: "Handcrafted Gold Brooch with Sapphire." Avoid vague terms like "Decorative Item." |
| De Minimis Shipment (Under $800) |
Caution: While some low-value items may enter duty-free under Section 321, jewelry from China is often scrutinized. Verify if Section 301 duties apply to de minimis shipments (policy changes frequently). |
🌍 5. Global Market Comparison (Brief)
| Country/Region | Recommended HS Code | Est. Duty (China Origin) | Notes |
|---|---|---|---|
| 🇺🇸 USA | 7113.19.50.91 / 7117.90.90.00 |
23.0% (Precious) 28.5% (Imitation) |
Section 301 tariffs apply. High compliance risk. |
| 🇪🇺 EU | 7113.19 / 7117.90 |
~4.3% (Precious) ~4.5% (Imitation) |
No Section 301. VAT applies separately. |
| 🇨🇳 China | 7113.19 / 7117.90 |
10% (Standard) | Import duty + VAT. |
| 🇬🇧 UK | 7113.19 / 7117.90 |
~4.3% (Precious) | Post-Brexit rules apply. |
📌 Conclusion:
- The US market is the most expensive for brooches due to the Section 301 tariffs.
- For imitation jewelry, the 28.5% total tax is a significant cost driver. Consider pricing strategies or supply chain adjustments.
📌 6. Common Mistakes & Pitfalls (Lessons Learned)
❌ Mistake 1: Declaring Gold Brooches as "Imitation Jewelry" to simplify description
👉 Consequence: Customs may seize goods, impose penalties, and reclassify, leading to 23% duty + fines.
❌ Mistake 2: Using vague terms like "Jewelry Accessory"
👉 Consequence: Delayed clearance, additional customs examination, potential reclassification to a higher-duty item.
❌ Mistake 3: Assuming De Minimis ($800) exemption applies to all brooches
👉 Consequence: If Section 301 duties are enforced on low-value shipments, the 23-28.5% tax will be charged, plus possible brokerage fees.
✅ Correct Approach:
"Gold Brooch, 14k, with Sapphire, Weight: 5g, Origin: China"
OR
"Imitation Jewelry Brooch, Zinc Alloy, Rhodium Plated, Origin: China"
🎯 7. Conclusion: Precision Saves Money
🎯 Remember:
🔹 "Material is King": Precious vs. Base Metal defines the base duty.
🔹 "Section 301 is Always On": For China-origin goods, expect the 10% add-on.
🔹 "Total Tax is Key": 23% vs 28.5% matters for high-volume sales.
📌 Pro Tip:
If you are importing imitation jewelry in bulk, consider pre-classification rulings from CBP to confirm the exact HS Code and ensure no additional anti-dumping duties apply.
For precious metals, ensure you have assay certificates ready for customs inspection.
📣 Take Action:
📞 Consult a Licensed Customs Broker to confirm the specific material composition requirements for
7113.19.50.91vs7113.19.50.95.
🚀 Optimize Your Supply Chain to manage the 23-28.5% tariff burden efficiently.
✨ Accurate Classification, Smooth Clearance, Maximum Profit!
💼 Your Brooches Deserve the Right Code!
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) — Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) — More specific grouping within the chapter
- Subheading (6 digits) — Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) — 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 — The standard duty rate applied to WTO members
- General rate — Applied to countries without trade agreements
- Trade remedy duties — 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.