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CN → US
HS Code Tariff Rate Origin Destination Doc
9603306000 10.0% CN US Official Doc
8205593080 35.0% CN US Official Doc
9603304000 17.5% CN US Official Doc
8205598000 38.7% CN US Official Doc
9017800000 40.3% CN US Official Doc

AI Analysis

💄 Point-Acne Pen / Mole Removal Pen (Cosmetic & Manual Tools)


🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
📌 1. Product Definition & Classification: Do You Really Understand the "Mole Removal Pen"?

The "Point-Acne Pen" or "Mole Removal Pen" is a specialized tool used for manual application of chemical agents (such as acid-based solutions) or physical marking/removal of skin imperfections. In international trade, its classification depends heavily on whether it is viewed as a cosmetic tool or a manual mechanical tool.

Manual Chemical Applicators/Markers: Used for precise application of substances, similar to writing instruments or cosmetic brushes. Manual Drilling/Marking Tools: Used for physical puncturing or positioning, classified under general hand tools.

⚠️ Key Distinction:
- If the device is primarily for cosmetic/artistic application (like a brush or pen) →归类 to 9603.30 series
- If the device is primarily for mechanical drilling/puncturing (hand tool function) →归类 to 8205.59 series
- If it is considered a general instrument for fine manual work →归类 to 9017.80


📦 2. HS Code Classification Details (2026 Latest Tariff Authority Reference)

HS Code Product Description Application Scenario Tariff Rate
9603.30.60.00 Artists' brushes, writing pens, and similar cosmetic brushes; tools for artistic creation or manual decoration Cosmetic marking pens, art tools, makeup applicators 10.0%
8205.59.30.80 Other hand tools (including tool sets); manual drilling or positioning tools Manual marking pens, physical point-drilling tools 35.0%
9603.30.40.00 Similar cosmetic brushes or writing-type tools Cosmetic pens, manual marking instruments 17.5%
8205.59.80.00 Other hand tools; manual drilling tools General manual drilling/puncturing pens 38.7%
9017.80.00.00 Other instruments/apparatus; drawing, marking, or measuring instruments Fine manual operation instruments, precision marking tools 40.3%

🔍 Key Reminder:
- If the pen is marketed as a cosmetic tool (e.g., for makeup, acne treatment), 9603 codes are more likely, but Section 122 duties may apply. - If the pen is marketed as a mechanical tool (e.g., for drilling, physical puncture), 8205 codes are more likely, with higher Section 122 duties. - Misclassification can lead to significant tariff differences (from 10% to 40.3%).


💰 3. 2026 Latest Tariff Rate Details (Including Additional Taxes & Policy Add-ons)

Applicable Country: United States (US)
Origin: China (CN)
Effective Time: From November 10, 2025 (including subsequent imports)

🎯 1. 9603.30.60.00 —— Artists' Brushes / Cosmetic Brushes (Artistic/Manual Application)

Item Content
Base Tariff 0% (ad valorem)
Section 301 Additional Tariff +0% (No 301 duty for this specific subheading in some interpretations, but see note below)
Section 122 Tariff +10% (Specific to China-origin goods under certain administrative rules)
Total Rate 10.0%
Tax Calculation CIF Value × 10%
De Minimis Eligibility No (If applicable under current rules for this code)
Legal Basis Path Section 122: 10%USITC: 9603.30.60.00

📌 Explanation:
- This code is often used for cosmetic brushes or artistic tools. - The 10% Section 122 duty applies specifically to Chinese-origin goods for certain categories. - No Section 301 (25%) applies here, making it the lowest cost option if the product qualifies.


🎯 2. 8205.59.30.80 —— Other Hand Tools (Manual Drilling/Positioning)

Item Content
Base Tariff 0% (ad valorem)
Section 301 Additional Tariff +25% (Standard 301 duty for Chinese hand tools)
Section 122 Tariff +10%
Total Rate 35.0%
Tax Calculation CIF Value × 35%
De Minimis Eligibility No
Legal Basis Path Section 301: 25%Section 122: 10%USITC: 8205.59.30.80

📌 Note:
- If the pen is classified as a hand tool (e.g., for physical puncturing), the 25% Section 301 duty applies. - Plus 10% Section 122 → Total 35%. - This is a high-risk code for cost control.


🎯 3. 9603.30.40.00 —— Similar Cosmetic/Writing Tools

Item Content
Base Tariff 0%
Section 301 Additional Tariff +7.5% (Partial 301 duty for some cosmetic tools)
Section 122 Tariff +10%
Total Rate 17.5%
Tax Calculation CIF Value × 17.5%
De Minimis Eligibility No
Legal Basis Path Section 301: 7.5%Section 122: 10%USITC: 9603.30.40.00

📌 Note:
- This code is for cosmetic brushes or writing-like tools. - 7.5% Section 301 applies to some cosmetic tools, not all. - Total 17.5%, a moderate cost option.


🎯 4. 8205.59.80.00 —— Other Hand Tools (Manual Drilling)

Item Content
Base Tariff 3.7%
Section 301 Additional Tariff +25%
Section 122 Tariff +10%
Total Rate 38.7%
Tax Calculation CIF Value × 38.7%
De Minimis Eligibility No
Legal Basis Path Base: 3.7%Section 301: 25%Section 122: 10%USITC: 8205.59.80.00

📌 Note:
- Base tariff 3.7% applies to general hand tools. - Plus 25% Section 301 + 10% Section 122 → Total 38.7%. - Highest cost option for hand tool classification.


🎯 5. 9017.80.00.00 —— Other Instruments (Fine Manual Operation)

Item Content
Base Tariff 5.3%
Section 301 Additional Tariff +25%
Section 122 Tariff +10%
Total Rate 40.3%
Tax Calculation CIF Value × 40.3%
De Minimis Eligibility No
Legal Basis Path Base: 5.3%Section 301: 25%Section 122: 10%USITC: 9017.80.00.00

📌 Note:
- Classified as an instrument for fine manual work. - Base tariff 5.3% + 25% Section 301 + 10% Section 122 → Total 40.3%. - Highest overall rate.


🛠️ 4. Customs Clearance Practical Advice (Avoiding Pitfalls)

✅ 1. Preparation Checklist (Essential Documents)

Document Required Notes
✅ Product Specification Sheet ✔️ Must specify if it is a cosmetic applicator or mechanical tool. Include material, function, and usage.
✅ Product Photos ✔️ Clear images showing the pen tip, body, and any branding.
✅ Commercial Invoice ✔️ Must accurately describe the product as "Cosmetic Mole Removal Pen" or "Manual Marking Tool".
✅ Packing List ✔️ Detail contents to avoid "miscellaneous" classification.
✅ Third-Party Test Report ✔️ If claiming cosmetic use, provide safety data (e.g., non-toxic, suitable for skin).
✅ HS Code Ruling Request ✔️ Highly Recommended to pre-classify and avoid disputes.

✅ 2. Declaration Tips (Key Strategy)

🔥 "Define Function Clearly, Avoid 'Tool' Ambiguity, Choose Low-Tariff Code!"

Scenario Correct Declaration Incorrect Declaration
Cosmetic Acne Pen 9603.30.60.00 or 9603.30.40.00 8205.59.80.0038.7% vs 10%
Mechanical Drilling Pen 8205.59.30.80 9603.30.60.00 → Risk of penalty if used for drilling
General Marking Tool 9603.30.40.00 9017.80.00.0040.3% vs 17.5%

📌 Key Strategy:
- If the product is primarily for cosmetic use (applying solution to acne/moles), declare as cosmetic brush/applicator (9603). - If the product is primarily for mechanical use (drilling/puncturing), declare as hand tool (8205). - Never declare a cosmetic pen as a "general instrument" (9017) if it fits 9603, as the tariff difference is huge.


✅ 3. Special Cases

Scenario Handling Advice
OEM Custom Pens Provide design drawings to prove cosmetic intent.
Combined Packaging If sold with solution bottles, declare the pen as the main item; solution may be classified separately.
Medical Claims If marketed as a "medical device," additional FDA regulations may apply, but HS classification remains similar.
Multi-Function Tools If the pen has both cosmetic and drilling functions, consult a customs broker for the primary use test.

🌍 5. Global Market Comparison (2026 Latest)

Country/Region Recommended HS Code Tariff Certification Notes
🇺🇸 USA 9603.30.60.00 10% FDA (if cosmetic) Lowest US tariff if correctly classified.
🇨🇳 China 9603.30.60.00 0-5% CCC (if applicable) Low cost in domestic market.
🇪🇺 EU 9603.30.60.00 0-4.5% CE + CPNP No Section 122 duties.
🇦🇺 Australia 9603.30.60.00 5% TGA (if medical) Moderate cost.
🇯🇵 Japan 9603.30.60.00 0-3% PSE (if electrical) Low cost.

📌 Conclusion:
- USA is the most critical market due to Section 122 and Section 301 duties. - Correct classification as cosmetic tool (9603) can save up to 30% in tariffs compared to hand tool (8205) or instrument (9017). - Pre-classification ruling is highly recommended for US imports.


📌 6. Common Mistakes & Pitfalls (Lessons Learned)

Mistake 1: Classifying a cosmetic pen as a "hand tool" (8205.59.80.00)
👉 Consequence: Tariff jumps from 10% to 38.7%Loss of profit!

Mistake 2: Declaring the product as "general instrument" (9017.80.00.00)
👉 Consequence: Tariff jumps to 40.3%Unnecessary cost.

Mistake 3: Using ambiguous terms like "Mole Removal Device" without specifying function
👉 Consequence: Customs may classify as hand toolHigher duty.

Mistake 4: Ignoring Section 122 duties
👉 Consequence: Even if base duty is 0%, 10% Section 122 still applies to Chinese-origin goods.

Correct Approach:

"Cosmetic Mole Removal Pen, Handheld, for Topical Application of Acne Treatment Solution, Model XYZ, Non-Electrical"


🎯 7. Conclusion: Professional Classification Saves Money!

🎯 Remember the Key:

🔹 "Cosmetic Use = 9603 (10-17.5%)"
🔹 "Drilling/Marking = 8205 (35-38.7%)"
🔹 "Instrument = 9017 (40.3%)"
🔹 "Choose 9603 if possible to save up to 30%!"


📌 Pro Tip:

If your product is OEM or private label, provide design specifications to prove cosmetic intent.
Consider applying for a Pre-Classification Ruling from US Customs to avoid surprises.


📣 Immediate Action:

📞 Contact a licensed customs broker + Provide product photos + Request HS Code ruling
🚀 Ensure smooth clearance, minimize tariffs, maximize profit!


Professional clearance starts with accurate classification!
💼 Every percentage point in duty matters!

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.