梳子造型
CN → USAI Analysis
💇♀️ Comb Shape (Plastic/Animal/Hair Combs)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Level Clearance Strategy
📌 I. Product Definition and Classification: Do You Really Understand "Combs"?
Combs, as essential personal care tools, are widely used in daily hairdressing, pet grooming, and industrial settings. In international trade, they are primarily classified based on their material and manufacturing process. The most common commercial item is the plastic comb, which falls under Chapter 39.
Key Classification Distinctions:
- Plastic Combs (Most Common): Made of cellulose acetate, polypropylene, ABS, etc. → HS 9615.
- Animal/Horn/Ivory Combs: Made from natural materials like tortoiseshell, horn, or ivory (restricted/prohibited) → HS 9615 (but with strict CITES/customs controls).
- Metal Combs: Made of stainless steel, titanium, etc. → HS 8214 (Cutlery/Hairdressing articles) or HS 7323 (if considered kitchenware-like, but usually 8214 for hairdressing).
- Wooden Combs: Made of bamboo, sandalwood, etc. → HS 4417 (Wooden brushes/combs) or HS 9615 (if processed similarly to plastic, but often 4417 is safer for pure wood).
⚠️ Critical Distinction:
- If the comb is plastic, horn, bone, wood, or bristle → It belongs to HS 9615.
- If the comb is metal (e.g., stainless steel fine-tooth comb) → It belongs to HS 8214.
- Ivory/Tortoiseshell items are subject to CITES restrictions and may be banned in some countries (e.g., US, EU, China).
📦 II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Applicable Scenario | Material | Contains Motor/Electric? |
|---|---|---|---|---|
9615.11.00.00 |
Combs, hair rollers, and similar articles, of hard rubber or plastics | Plastic combs, hair styling tools | Plastic (PP, ABS, etc.) | ❌ No |
9615.19.00.00 |
Other combs, of hard rubber or plastics | Plastic combs with special shapes | Plastic | ❌ No |
9615.90.00.00 |
Combs, hair rollers, and similar articles, of other materials | Wood, bone, horn, animal hair, metal (if classified here by some customs, but see below) | Wood, Horn, Bone, etc. | ❌ No |
8214.20.00.00 |
Hair-cutting scissors and similar articles, and parts thereof | Metal hairdressing scissors, metal razors | Metal | ❌ No |
9603.90.00.00 |
Brushes, including brushes used as parts of machines; prepared knots and tufts for brushmaking | Bristle combs (rare), brush handles | Bristles, Wire | ❌ No |
4417.00.00.00 |
Tool blocks, tool handles, tool bodies, tool backs, and similar article, of wood; wooden flatware | Wooden combs, bamboo combs | Wood, Bamboo | ❌ No |
🔍 Key Reminder:
- Plastic combs are overwhelmingly classified under9615.11.00.00or9615.19.00.00.
- Metal combs are often misclassified. If it’s a hairdressing tool made of metal, it may fall under8214.20.00.00(though this is more for scissors/razors, some customs accept metal combs here; however,9615.90.00.00is also commonly used for "other materials" including metal if not explicitly covered elsewhere. Check local customs practice).
- Wooden/Bamboo combs can be classified under9615.90.00.00or4417.00.00.00.9615.90.00.00is generally preferred for finished combs.
- Ivory/Tortoiseshell combs: HS 9601 (Ivory) or 9602 (Tortoiseshell). Strictly regulated!
💰 III. 2026 Latest Tariff Rate Details (Including Surcharges, Policy Surcharges)
✅ Applicable Country: United States (US)
✅ Origin: China (CN)
✅ Effective Date: From November 10, 2025 (including subsequent imports)
🎯 1. 9615.11.00.00 —— Combs, of hard rubber or plastics
| Item | Content |
|---|---|
| Basic Tariff Rate | 0% (ad valorem) |
| USITC Surtax | +25% (from USITC Footnote 9903.88.01, Section 301) |
| IEEPA Surtax | +10% (for China/HK products, from Nov 10, 2025) |
| Total Tariff Rate | 35% |
| Tax Calculation | CIF Value × 35% |
| De Minimis Eligible? | ❌ No (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.25 → IEEPA:9903.01.24 → USITC:9615.11.00.00 → FOOTNOTE:9903.88.01 |
📌 Explanation:
- "USITC Surtax 25%" comes from Section 301 of the US Trade Act;
- "IEEPA 10%" is the additional tariff imposed on Chinese goods under the International Emergency Economic Powers Act;
- Total 35%, which is a high tariff. Must be factored into pricing!
🎯 2. 9615.19.00.00 —— Other combs, of hard rubber or plastics
| Item | Content |
|---|---|
| Basic Tariff Rate | 0% |
| USITC Surtax | +25% |
| IEEPA Surtax | +10% |
| Total Tariff Rate | 35% |
| Tax Calculation | CIF × 35% |
| De Minimis Eligible? | ❌ No |
| Legal Basis Path | IEEPA:9901.25 → IEEPA:9903.01.24 → USITC:9615.19.00.00 → FOOTNOTE:9903.88.01 |
📌 Note:
- Same rate as above; applies to all plastic combs regardless of shape (wide-tooth, fine-tooth, round, etc.).
- De Minimis (Section 321) is not available for these goods.
🎯 3. 9615.90.00.00 —— Combs, of other materials (Wood, Horn, etc.)
| Item | Content |
|---|---|
| Basic Tariff Rate | 0% |
| USITC Surtax | +25% |
| IEEPA Surtax | +10% |
| Total Tariff Rate | 35% |
| Tax Calculation | CIF × 35% |
| De Minimis Eligible? | ❌ No |
📌 Note:
- Even wooden or bamboo combs face the same 35% surtax if from China.
- CITES Restrictions: If made from protected species (e.g., sandalwood, tortoiseshell), additional permits are required.
🎯 4. 8214.20.00.00 —— Metal Combs (if classified here)
| Item | Content |
|---|---|
| Basic Tariff Rate | 0% |
| USITC Surtax | +25% |
| IEEPA Surtax | +10% |
| Total Tariff Rate | 35% |
| Tax Calculation | CIF × 35% |
| De Minimis Eligible? | ❌ No |
📌 Note:
- Metal hairdressing tools also face the same surtaxes.
- Some customs brokers may classify metal combs under 9615.90.00.00 to simplify, but check with customs for accuracy.
🛠️ IV. Customs Clearance Practical Advice (Real-World Pitfall Avoidance Guide)
✅ 1. Required Documents Checklist (All or Nothing)
| Document | Required | Description |
|---|---|---|
| ✅ Product Specification Sheet | ✔️ | Material, size, tooth count, weight, packaging details |
| ✅ Material Declaration | ✔️ | Specify if plastic, wood, metal, or animal product |
| ✅ Product Photos | ✔️ | Clear images of front, back, teeth, and packaging |
| ✅ Certificate of Origin (CO) | ✔️ | If non-China origin, may qualify for lower tariffs |
| ✅ Commercial Invoice | ✔️ | Clearly state "Plastic Comb" or "Wooden Comb" |
| ✅ Packing List | ✔️ | Include gross weight, net weight, dimensions |
| ✅ CITES Permit (if applicable) | ✔️ | For ivory, tortoiseshell, or certain woods |
✅ 2. Declaration Tips (Key Mantra)
🔥 “Material First, Shape Second, Name Specific, Tariff Clear!”
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Plastic Comb | 9615.11.00.00 |
Misdeclared as "Hair Tool" → 35% + Risk |
| Wooden Comb | 9615.90.00.00 or 4417.00.00.00 |
Misdeclared as Plastic → Penalty |
| Metal Comb | 8214.20.00.00 or 9615.90.00.00 |
Misdeclared as Plastic → Inaccuracy |
| Tortoiseshell Comb | 9602.00.00.00 + CITES |
Misdeclared as Plastic → Seizure & Fine |
✅ 3. Special Circumstances Handling
| Scenario | Handling Advice |
|---|---|
| OEM Custom Combs | Provide customer order + design specs. Avoid generic names like "Comb." Use "Plastic Hair Comb, Model XYZ." |
| Comb with Electric Motor (e.g., Electric Curling Iron) | Not a "comb" under 9615. Likely 8516 (Electric Hair Dryers/Irons). Different tariff! |
| Comb Made from Protected Wood | Requires CITES permit. Without it, seized and destroyed. |
| Comb Set (with Brush, Mirror) | Declare each item separately if possible. Mirror under 7009 or 7320, Brush under 9603. |
🌍 V. Global Main Market Customs Clearance Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff | Certification Requirements | Notes |
|---|---|---|---|---|
| 🇺🇸 USA | 9615.11.00.00 |
35% (China) | FDA (if food-contact? No), CPSIA (if for kids) | 35% total |
| 🇨🇳 China | 9615.11.00.00 |
0% | CCC (if electric? No) | No surtax |
| 🇪🇺 EU | 9615.11.00.00 |
0% (Most Favored Nation) | CE (if electrical? No), REACH (plastics) | Low tariff |
| 🇦🇺 Australia | 9615.11.00.00 |
5% | RCM (if electrical? No) | Low tariff |
| 🇯🇵 Japan | 9615.11.00.00 |
0% | PSE (if electrical? No) | No surtax |
📌 Conclusion:
- USA is the only market with significant surtaxes (35%).
- China, EU, Japan, Australia have 0%~5% tariffs.
- Cost advantage: Consider non-China origins (e.g., Vietnam, India) to avoid US surtaxes.
📌 VI. Common Errors & Pitfall Guide (Lessons Learned)
❌ Error 1: Declaring "Comb" as "Hair Accessory" without material specification
👉 Consequence: Customs delays, potential penalty for incorrect classification.
❌ Error 2: Misdeclaring wooden comb as plastic
👉 Consequence: If checked, misdeclaration penalty + back taxes.
❌ Error 3: Importing tortoiseshell comb without CITES permit
👉 Consequence: Seizure, fines, and criminal charges in US/EU.
❌ Error 4: Combining electric hair tools with manual combs in one package without clear breakdown
👉 Consequence: Misclassification risk. Declare separately.
✅ Correct Practice:
“Plastic Hair Comb, 20cm, 50 teeth, PP Material, No Electric Components, Model ABC”
🎯 VII. Conclusion: Professional Declaration, Time-Saving, Cost-Effective!
🎯 Remember the Mantra:
🔹 “Material Dictates HS, Shape is Secondary. Plastic 35%, Wood 35%, Ivory is Illegal!”
🔹 “HS Code is Life, 35% Tariff is Pain, Declaration is Key, Penalty is Gain (for Customs)!”
📌 Tips:
- If your combs are originated from Vietnam, India, Indonesia, you may avoid US IEEPA/301 surtaxes, reducing tariff to 0%~5%.
- For children’s combs, ensure compliance with CPSIA (US) or EN71 (EU) for safety.
- Consider Advance Ruling if unsure about classification.
📣 Immediate Action:
📞 Contact Professional Customs Broker + Provide Product Photos + Apply for HS Code Advance Ruling
🚀 Let your combs clear customs smoothly, export efficiently, and boost profits!
✨ Professional Customs Clearance Starts with Accurate Classification!
💼 Every Penny of Your Cost Deserves Precise Calculation!
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.