衣服梳

👗 Clothes Combs (Garment Brushing Tools)

🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
📌 I. Product Definition & Classification: What Exactly is a "Clothes Comb"?

"衣服梳" (Clothes Comb) is a generic term often used in casual translation. In international trade and customs classification, it is strictly categorized based on its material and primary function. It is not a single HS code but splits into two main categories:

1. Plastic Household Articles: If made primarily of plastic, used for removing lint, pet hair, or wrinkles from fabrics.
   • HS Chapter: 39 (Plastics and articles thereof)
2. Brushes (Toilet/Hair Brushes): If made of natural fibers (boar bristle, human hair) or synthetic filaments, used for grooming clothes.
   • HS Chapter: 96 (Brooms, brushes, mops, feather dusters, prepared knots and tufts for broom or brush making; paint pads and rollers; squeegees (other than roller squeegees): Toothbrushes, shaving brushes, hair brushes, nail brushes, eyelash brushes and other toilet brushes for use on the person, including such brushes constituting parts of appliances: Other**

⚠️ Critical Distinction:
- If it is a plastic scraper/combo with no bristles → Chapter 39
- If it has bristles, teeth, or fibers for brushing → Chapter 96
- Do NOT classify plastic clothes combs as "Toiletries" or "Hair Brushes" unless they are explicitly designed for personal grooming (hair/scalp) and marketed as such. However, customs often groups general grooming brushes under 9603.

📦 II. HS Code Classification Details (Based on Provided Data)

The provided data contains three specific HS codes. We must analyze which ones apply to "Clothes Combs" and exclude those that do not.

🔍 Key Insight:
- Plastic Lint Removers (No Bristles): Likely 3924.90.56.50 (10.9%) or 3924.10.40.00 (3.4%).
- Brush-Type Clothes Combs (With Bristles/Teeth): Likely 9603.29.80.90 (0.0%).
- Why is 9603.29.80.90 0%? It appears to be exempt from additional tariffs in the provided data. This is a critical cost-saving opportunity if the product has any bristle-like structure.

💰 III. Detailed Tariff Breakdown (Based on DATA)

✅ Applicable Countries: United States (US)
✅ Origin: China (CN) (Assumed based on typical 3.4% base rate context)
✅ Validity: Current data as provided

🎯 1. 9603.29.80.90 —— Brush-Type Clothes Combs (Best Case Scenario)

📌 Explanation:
- This code falls under "Other toilet brushes for use on the person."
- Controversy: Is a clothes comb a "toilet brush for use on the person"?
- Customs Practice: Many customs brokers argue that fabric brushes are not for "the person" but for "articles." However, if the brush resembles a hairbrush or nail brush in design, it may be accepted under this code.
- Risk: Low if structured as a brush; High if classified as plastic household article.
- Advantage: 0% tax is the most favorable outcome.

🎯 2. 3924.10.40.00 —— Plastic Tableware/Kitchenware (Unlikely)

📌 Explanation:
- Only applicable if the item is a solid plastic lint scraper with no bristles.
- Not typically used for grooming brushes.
- Moderate tax rate.

🎯 3. 3924.90.56.50 —— Other Plastic Household Articles (Worst Case for Plastic Items)

📌 Explanation:
- This is the fallback code for plastic items not classified elsewhere.
- If customs rejects 9603.29 (brush) and 3924.10 (tableware), it may land here.
- Highest tax rate among the three options for plastic items.

🛠️ IV. Customs Clearance Practical Advice (Avoiding Pitfalls)

✅ 1. Product Design & Material Strategy

🚨 Critical Warning:
- Do NOT describe a bristle-covered clothes comb as "Plastic Tableware." It will be misclassified, leading to audits.
- Do NOT describe a solid plastic lint scraper as a "Brush." It lacks bristles/fibers.

✅ 2. Documentation & Declaration Tips

🔥 Declaration Keyword Strategy:
- For 9603.29.80.90: Use "Fabric Brush," "Lint Brush," "Clothing Grooming Brush."
- For 3924.10.40.00: Use "Plastic Lint Remover," "Static Charge Cleaner."
- Avoid: "Toothbrush" or "Hair Brush" unless it looks exactly like one. Use "Other Toilet Brush for Use on the Person" as the technical term if claiming 9603.

✅ 3. Special Cases

🌍 V. Global Market Comparison (2026 Latest)

📌 Conclusion:
- USA offers 0% tax for brush-type clothes combs under 9603.29.80.80.90 IF correctly classified.
- Plastic-only lint removers face 3.4%-10.9% tax.

📌 VI. Common Errors & Pitfalls (Lessons Learned)

❌ Error 1: Classifying a bristle brush as 3924.90.56.50 (Plastic Household).
👉 Consequence: Pay 10.9% instead of 0.0%. Loss: 10.9% of CIF value.

❌ Error 2: Classifying a solid plastic scraper as 9603.29.80.90 (Brush).
👉 Consequence: Customs rejects it, delays shipment, reclassifies to 3924.90.56.50 (10.9%). Penalties + Delay.

❌ Error 3: Vague Description "Clothes Comb."
👉 Consequence: Customs officer uses discretion, likely picking the higher tax rate (3924.90.56.50) to be safe.

✅ Correct Approach:

"Synthetic Bristle Fabric Grooming Brush for Removing Pet Hair and Lint from Clothing, 100% Nylon Bristles, ABS Handle, Model ABC"

🎯 VII. Conclusion: Maximize Savings with Correct Classification

🎯 Key Takeaway:

🔹 Brush with Bristles/Teeth → 9603.29.80.90 → 0.0% Tax 🎉
🔹 Solid Plastic Scraper → 3924.10.40.00 → 3.4% Tax
🔹 Unclear/Other Plastic → 3924.90.56.50 → 10.9% Tax ⚠️

🔹 "If it brushes, it’s 9603. If it scrapes, it’s 3924."
🔹 "0% tax is possible! Don’t let vague descriptions cost you 10.9%."

📌 Pro Tip:
If your product has any bristle, fiber, or tooth-like structure designed for grooming, insist on 9603.29.80.90. Provide clear photos and descriptions emphasizing "Brush" functionality. This can save significant costs compared to the 10.9% plastic household rate.

📣 Immediate Action:

📞 Confirm product structure: Bristles? → Yes → 9603.29.80.90 (0.0%)
📸 Take high-res photos showing bristles/teeth.
📄 Update commercial invoice description to "Fabric Grooming Brush."
🚀 Clear customs smoothly and save 10.9% in taxes!

✨ Professional classification saves money!
💼 Every dollar of tax saved is pure profit!