衣物梳
CN → USAI Analysis
🖌️ Clothing Brush / Fabric Shaver (Garment Care Tools)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
📌 I. Product Definition & Classification: Do You Know What a "Clothing Brush" Is?
"Clothing Brush" is a generic term that covers a wide range of products used for garment maintenance, from simple natural bristle brushes to electric fabric shavers and lint rollers. In international trade, classification depends strictly on the material, mechanism, and intended use. Misclassification is the #1 cause of customs delays for textile accessories.
Two Main Categories:
-
Non-Electric Manual Brushes (Bristle/Fiber Brushes):
Used for cleaning dust, pet hair, or wrinkles from suits, coats, and upholstery. Typically made of plastic handles with natural (badger/hog) or synthetic bristles.
→ Classified under Chapter 96 (Miscellaneous Manufactured Articles) or Chapter 42 (Articles of Leather/Travel Goods) depending on specific design. -
Electric Fabric Shavers / Depillers (Lint Removers):
Battery-operated or plug-in devices with a motor, cutter blade, and mesh head to remove "pills" (fabric balls) and lint.
→ Classified under Chapter 85 (Electrical Machinery & Equipment) because it contains a motor.
⚠️ Key Distinction Point:
- If it has no motor/battery and is just a brush handle + bristles → 9603 or 4203.
- If it has a motor, blade, and battery to shave fabric → 8510.
- If it is a roll with adhesive (Lint Roller) → 4823 or 3919.
📦 II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Application Scenario | Contains Motor? |
|---|---|---|---|
9603.90.89.00 |
Other brushes (including brushes constituting parts of machines), hand-operated mechanical floor sweepers, mops and feather dusters | Non-electric clothing brushes (plastic/natural bristle), suit brushes, hat brushes | ❌ No |
4203.21.00.00 |
Articles of clothing accessories of leather or composition leather | Specialized leather-handled garment brushes or cases | ✅ No (Material based) |
8510.20.00.00 |
Hand-held electric hair clipper, shaver, or beard trimmer | Electric fabric shavers, lint removers, pill removers with motor | ✅ Yes |
8510.90.00.00 |
Parts suitable for use solely or principally with the articles of heading 8510 | Replacement cutter heads, blades for fabric shavers | ❌ No (Part only) |
4823.69.00.00 |
Sheets, strips, paper and paperboard of a kind used for domestic or toilet purposes | Lint roller refills, adhesive paper rolls | ❌ No |
3919.90.40.00 |
Self-adhesive plates, sheets, film, foil, strip and other flat shapes, in rolls | Lint roller core/roll itself (plastic/paper base with adhesive) | ❌ No |
🔍 Critical Reminder:
- Electric Fabric Shavers are frequently misclassified under9603(brushes). This is WRONG. If it has a motor, it MUST be8510.20.00.00.
- Replacement Blades for shavers are classified as8510.90.00.00, not8510.20.00.00.
- Lint Rollers (the adhesive tape part) are often classified under4823or3919depending on the backing material.
💰 III. 2026 Latest Tariff Rate Breakdown (Including Surcharges & Policy Add-ons)
✅ Applicable Country: United States (US)
✅ Origin: China (CN)
✅ Effective Date: From November 10, 2025 (including subsequent imports)
🎯 1. 9603.90.89.00 —— Other Brushes (Non-Electric Clothing Brush)
| Item | Content |
|---|---|
| Base Tariff | 3.4% (ad valorem) |
| USITC Surcharge | 0% (Most brushes are excluded from Section 301) |
| IEEPA Surcharge | 0% (General consumer goods often exempt or low rate) |
| Total Tariff | 3.4% |
| Tax Calculation | CIF Value × 3.4% |
| De Minimis Eligibility | ✅ Yes (Usually eligible under $800) |
| Legal Basis Path | HTSUS:9603.90.89 → No specific Section 301 footnote for general brushes |
📌 Explanation:
- Most manual clothing brushes are not subject to heavy Section 301 tariffs.
- This is a low-risk, low-cost clearance category.
- Ensure the product description explicitly states "Non-Electric" to avoid being audited as an electrical device.
🎯 2. 8510.20.00.00 —— Electric Fabric Shaver (Lint Remover)
| Item | Content |
|---|---|
| Base Tariff | 1.7% |
| USITC Surcharge | +25% (From USITC Footnote 9903.88.01, Section 301) |
| IEEPA Surcharge | +10% (For China/HK products, effective Nov 10, 2025) |
| Total Tariff | 36.7% |
| Tax Calculation | CIF Value × 36.7% |
| De Minimis Eligibility | ❌ No (Deny de minimis) |
| Legal Basis Path | IEEPA:9903.01.25 → IEEPA:9903.01.24 → USITC:8510.20.00.00 → FOOTNOTE:9903.88.01 |
📌 Note:
- Electric fabric shavers are classified as "hand-held electrical appliances."
- 36.7% is a high tariff. Importers must account for this in pricing.
- These items are NOT eligible for the $800 de minimis exemption (Section 321) if shipped from China.
🎯 3. 8510.90.00.00 —— Parts for Electric Shavers (Replacement Blades)
| Item | Content |
|---|---|
| Base Tariff | 1.7% |
| USITC Surcharge | +25% |
| IEEPA Surcharge | +10% |
| Total Tariff | 36.7% |
| Tax Calculation | CIF Value × 36.7% |
| De Minimis Eligibility | ❌ No |
📌 Warning:
- Spare blades for electric shavers carry the same high tariff as the main unit.
- Do not try to label them as "plastic parts" (3926) to avoid tariffs; customs will inspect and reclassify, leading to penalties.
🛠️ IV. Customs Clearance Practical Advice (Battle-Tested Pitfall Guide)
✅ 1. Document Checklist (Essential)
| Document | Required | Description |
|---|---|---|
| ✅ Product Spec Sheet | ✔️ | Must clearly state "Electric" vs. "Manual," voltage, battery type. |
| ✅ Circuit Diagram | ✔️ | For electric shavers, proves presence of motor (supports HS 8510). |
| ✅ Product Photos | ✔️ | Clear shots of brand, model, input voltage, and power button. |
| ✅ FCC Certification | ✔️ | Mandatory for all electric devices imported into the US. |
| ✅ Commercial Invoice | ✔️ | Must specify "Electric Fabric Shaver" NOT "Clothing Brush" (to avoid confusion). |
| ✅ Battery Declaration | ✔️ | If lithium-ion, must include UN38.3 test report and MSDS. |
✅ 2. Declaration Tips (Key Mantra)
🔥 "Electric is 85, Manual is 96, Blades are Parts, Don't Mix!"
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Electric Lint Remover | 8510.20.00.00 - "Electric Fabric Shaver" |
Labeling as "Clothing Brush" (HS 9603) → Audit Risk |
| Non-Electric Suit Brush | 9603.90.89.00 - "Hair Brush" or "Suit Brush" |
Labeling as "Electrical Appliance" → Unnecessary 36.7% Tax |
| Replacement Blade | 8510.90.00.00 - "Shaver Blade" |
Labeling as "Plastic Part" (HS 3926) → Customs Penalty |
| Lint Roller (Adhesive) | 4823.69.00.00 or 3919.90.40.00 |
Labeling as "Paper Product" only → Missing Adhesive Description |
✅ 3. Special Circumstances Handling
| Scenario | Handling Advice |
|---|---|
| Bundled Sets (Brush + Shaver) | Declare as a Set. The component that gives the set its essential character determines the HS Code. Usually, if it includes an electric shaver, classify as 8510. |
| Lithium Battery Included | Must declare battery capacity (Wh/Ah). If >100Wh, additional air freight restrictions apply. |
| OEM Custom Brushes | Provide design sketches to prove bristle material (natural vs. synthetic) if claiming under specific subheadings. |
| Gift Sets | If a luxury brush is packaged with a suit, it may be considered a "part of the garment" (HS 4203) rather than a brush (HS 9603). Get a pre-ruling. |
🌍 V. Global Market Comparison for Clothing Brushes (2026)
| Country/Region | Recommended HS Code | Tariff Rate | Certification Req. | Note |
|---|---|---|---|---|
| 🇺🇸 USA | 9603 (Manual) / 8510 (Electric) |
3.4% (Manual) / 36.7% (Electric) | FCC (for electric) | High tax on electric |
| 🇨🇳 China | 9603 / 8510 |
6-12% | CCC (for electric) | Moderate tax |
| 🇪🇺 EU | 9603 / 8510 |
0-4.5% | CE / RoHS | Low tax, strict safety |
| 🇬🇧 UK | 9603 / 8510 |
0-4.5% | UKCA | Post-Brexit alignment |
| 🇦🇺 Australia | 9603 / 8510 |
5% | RCM | Standard import tax |
📌 Conclusion:
- USA is the most aggressive market for electric garment care tools.
- EU/UK are friendlier for both manual and electric, but require CE/UKCA safety marks.
- Manual brushes face low tariffs globally, making them a safer export product for high-tariff zones.
📌 VI. Common Mistakes & Pitfalls (Lessons Learned)
❌ Mistake 1: Labeling an Electric Fabric Shaver as "Clothing Brush" (HS 9603)
👉 Consequence: Customs detects motor via X-ray/inspection. Re-classifies to 8510. Back taxes + 25% penalty + 30-day delay.
❌ Mistake 2: Shipping Replacement Blades for shavers as "Plastic Parts" (HS 3926)
👉 Consequence: Customs recognizes them as shaver parts. Charges 36.7% instead of potential lower rate. Overpayment.
❌ Mistake 3: Ignoring Battery Regulations for electric shavers
👉 Consequence: Shipment held at carrier hub due to missing UN38.3/MSDS. Return or Destruction.
❌ Mistake 4: Declaring Lint Rollers as "Paper" without mentioning adhesive
👉 Consequence: Misclassification. Lint rollers are composite goods. Audit trigger.
✅ Correct Approach:
"Electric Fabric Shaver, Model XYZ, 2000mAh Battery, FCC Certified, For Removing Lint and Pills"
🎯 VII. Conclusion: Precision Classification, Save Money, Speed Up Clearance!
🎯 Remember the Mantra:
🔹 "Manual = 96 (Low Tax), Electric = 85 (High Tax), Blades = Parts, Battery = Docs!"
🔹 "Don't call a shaver a brush! Save 30% in tariffs!"
🔹 "FCC is mandatory for electric, no FCC = No Entry!"
📌 Pro Tip:
If you export electric fabric shavers to the US, consider:
1. Supplier Diversification: Source from Vietnam/Malaysia to potentially avoid China-specific IEEPA tariffs (check rules of origin).
2. Pre-Ruling: Apply for an Import Advice from CBP if the product is unique.
3. Bundle Wisely: If selling a "Garment Care Kit," ensure the non-electric parts are clearly separated or value-shifted to optimize tax.
📣 Immediate Action:
📞 Verify HS Code: Double-check
8510vs9603before booking shipment.
📄 Prepare FCC: Ensure all electric devices have valid FCC IDs.
🚀 Clear Smoother: Correct classification today saves thousands in tomorrow's duties.
✨ Professional Clearance Starts with Accurate Classification!
💼 Every Dollar Saved on Tariffs is Pure Profit!
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.