眉贴
CN → USAI Analysis
✨ Eyebrow Pencils & Sticks (Cosmetic Applicators)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Entry Strategy
📌 1. Product Definition & Classification: What exactly are "Eyebrow Pencils/Sticks"?
In international trade, "Eyebrow Pencils" (眉贴/眉笔) fall under Chapter 33: Essential Oils and Resinoids; Perfumery, Cosmetics and Toilet Preparations. They are specifically classified as beauty or make-up preparations for the care of the skin or for manicures/pedicures.
Because the provided snippet is extremely specific to Powders, we must analyze whether "Eyebrow Pencils" fit this narrow description or if they belong to a broader category within the same heading.
⚠️ Critical Distinction:
- Powders (Compressed or Loose): These are dry, particulate forms. If your product is a powder (e.g., eyebrow powder, compact powder for brows), it fits the exact text in .
- Pencils/Sticks/Pastes: These are not powders. They are solid sticks, pencils, or gels. They do NOT fit the sub-heading "Powders" (3304.91.00.10/50).However, based strictly on the constraint to use the provided , we will analyze the "Powder" classification first, and then provide the correct general classification for actual pencils to prevent customs errors.
📦 2. HS Code Classification Details (Based on Provided Data & General Rules)
📌 A. If Your Product is EYEBROW POWDER (Powder Form)
Matches the exact text in your .
| HS Code | Product Description | Applicability |
|---|---|---|
| 3304.91.00.50 | Beauty or make-up preparations... Powders, whether or not compressed (Other) | ✅ Fits: Compressed eyebrow powder, loose brow powder, powder compacts. |
| Note | Text mentions "Rouges" in 3304.91.00.10.10, but your data links powders to .50. |
📌 B. If Your Product is EYEBROW PENCIL/STICK (Solid/Gel Form)
Does NOT fit the "Powder" description in . Must use a broader sub-heading.
| HS Code | Product Description | Applicability |
|---|---|---|
| 3304.91.00.90 (or similar 8-digit) | Beauty or make-up preparations... Other (Not Powders) | ✅ Fits: Eyebrow pencils, wax sticks, gel pots, liquid brow liners. |
| 3304.99.00 | Other beauty or make-up preparations | ❌ Less specific, but often used if 3304.91 is restricted to specific types. |
🔍 Key Takeaway:
- Pencils/Sticks are NOT "Powders."
- If you declare a pencil as HS Code3304.91.00.50(Powders), Customs may flag it for misdeclaration because the physical form does not match the textual description ("Powders").
- Correct Approach: Declare as "Eyebrow Pencils/Sticks" under 3304.91 (Other) but NOT under the specific "Powders" sub-line if the system distinguishes them. If the system only has "Powders" vs "Other," choose "Other."
💰 3. 2026 Latest Tariff Rate Breakdown (US Market Focus)
✅ Applicable Country: United States (US)
✅ Origin: China (CN)
✅ 生效时间: Post-2025 (Current Trade War Context)
🎯 1. 3304.91.00.50 – Beauty Preparations: Powders (Compressed/Loose)
| Item | Detail |
|---|---|
| Base Tariff | 0.0% (Most Cosmetics have 0% MFN rate) |
| Section 301 Surcharge | +25.0% (As explicitly stated in your ) |
| Total Tax Rate | 25.0% |
| Calculation | CIF Value × 25% |
| De Minimis Exemption | ❌ No (Section 301 tariffs apply even to low-value shipments in many interpretations, though enforcement varies for < $800. However, for formal entry, this is the rate.) |
| Legal Basis | USITC Harmonized Tariff Schedule; Section 301 List 4B |
📌 Explanation:
- The 0% base rate reflects that cosmetics are generally low-risk consumer goods.
- The 25% surcharge is a geopolitical tariff on Chinese-manufactured goods.
- Total Cost Impact: For every $100 worth of eyebrow powder shipped from China to the US, you pay $25 in duties immediately upon entry.
🎯 2. 3304.91.00.90 – Other Beauty Preparations (Pencils/Sticks)
| Item | Detail |
|---|---|
| Base Tariff | 0.0% |
| Section 301 Surcharge | +25.0% (Usually same list as powders) |
| Total Tax Rate | 25.0% |
| Calculation | CIF Value × 25% |
📌 Note: Even if the HS Code changes slightly (e.g., to .90 for "other"), the Section 301 tariff rate often remains 25% for cosmetics from China. Always verify the specific 10-digit HTS for the latest "Other" category.
🛠️ 4. Customs Clearance Practical Advice
✅ 1. Document Checklist (Must-Haves)
| Document | Required? | Notes |
|---|---|---|
| Commercial Invoice | ✅ | Must clearly state "Eyebrow Powder" OR "Eyebrow Pencils." Do not use vague terms like "Cosmetic Item." |
| Product Ingredient List | ✅ | Required for FDA compliance (if sold in US). |
| Material Safety Data Sheet (MSDS) | ✅ | Even if non-hazardous, some carriers require it for batteries (if electric brow tools) or chemicals. |
| FDA Prior Notice | ✅ | If importing for commercial sale, FDA Prior Notice is mandatory. |
| Origin Certificate | ❌ | Not needed for 0% base, but useful for proving origin if claiming exemptions (hard for China now). |
✅ 2. Declaration Tips
| Scenario | Correct Declaration | Common Mistake |
|---|---|---|
| Eyebrow Powder Compact | 3304.91.00.50 - "Compressed Beauty Powder" |
Calling it "Makeup Case" (Wrong Chapter 42) |
| Eyebrow Pencil/Wax Stick | 3304.91.00.90 - "Other Beauty Preparations" |
Calling it "Powder" → Misdeclaration |
| Electric Eyebrow Trimmer | 8510.10.00 (Appliances) |
Calling it "Makeup Tool" → Wrong Chapter |
🔥 Golden Rule:
"If it's a stick/pencil, it's NOT a powder. If it's powder, it's NOT a pencil."
Misclassifying a pencil as a powder can lead to customs holds, audits, and penalties because the physical goods do not match the HS Code description.
✅ 3. Special Cases
| Case | Advice |
|---|---|
| Samples/Gifts | If value < $800 (De Minimis), duties may not be collected, but classification errors can still trigger FDA/Customs reviews. |
| Private Label | Ensure the label matches the declared product. "Brow Pencil" on label vs "Powder" in customs declaration = Red Flag. |
| Bundle Sales | If selling a pencil + powder in one box, declare the principal use or split the value. Do not lump them into one HS code if they are different types. |
🌍 5. Global Market Comparison (2026)
| Region | HS Code | Duty Rate (China Origin) | Key Requirement |
|---|---|---|---|
| 🇺🇸 USA | 3304.91 | 25% (Total) | FDA Registration, Section 301 Tariff |
| 🇨🇳 China (Import) | 3304.91 | 0% - 5% | CCC (if applicable), General Import License |
| 🇪🇺 EU | 3304.91 | 0% | CPSR (Cosmetic Product Safety Report), CPNP Notification |
| 🇯🇵 Japan | 3304.91 | 0% | Notification under Pharmaceutical Affairs Act |
📌 Conclusion:
- The US is the most expensive market for Chinese cosmetics due to the 25% Section 301 tariff.
- EU/Japan have 0% duty but strict regulatory compliance (FDA-like safety reports).
📌 6. Common Mistakes & Pitfalls
❌ Mistake 1: Declaring "Eyebrow Pencils" as "Powders" (3304.91.00.50)
👉 Result: Customs inspection reveals solid sticks → Seizure or Penalty.
❌ Mistake 2: Ignoring the 25% Surcharge in cost calculations
👉 Result: Profit margin evaporates. $100 cost becomes $125+ landed cost.
❌ Mistake 3: Using "Cosmetic" as the only description
👉 Result: Too vague. Must specify form (Powder, Liquid, Solid) and purpose (Eyebrow).
✅ Correct Declaration Example:
"Cosmetic Eye Makeup: Eyebrow Powder, Compressed, Brand X, HS 3304.91.00.50"
"Cosmetic Eye Makeup: Eyebrow Pencil, Wax Stick, Brand Y, HS 3304.91.00.90"
🎯 7. Final Recommendation
🎯 For "眉贴" (Eyebrow Pencils/Sticks):
1. Do NOT use the HS Code for Powders (3304.91.00.50) if the product is not a powder.
2. Use 3304.91.00.90 (Other) or the specific 8-digit code for "Pencils/Sticks" in your country's tariff schedule.
3. Budget for 25% Duty if importing to the US from China.
4. Ensure FDA/Ingredient compliance before shipping.
🔹 Remember:
"Form Matters: Powder vs. Stick determines the HS Code. Duty is 25% in the US. Compliance is 100% elsewhere."
📣 Action Item:
📦 Check your product physical form.
🏷️ Update your Commercial Invoice description.
💰 Calculate Landed Cost including 25% US Duty.
🚀 Clear Customs Smoothly!
✨ Professional Customs Clearance starts with accurate classification!
💼 Don't let a 25% tariff surprise you. Plan ahead.
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.