Double headed Comb

🪮 Double-Headed Combs (Hair Brushes with Dual Heads)

🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
📌 1. Product Definition and Classification: Do You Really Understand "Double-Headed Combs"?

A double-headed comb (also known as a dual-sided hairbrush or reversible comb) typically features two functional heads on a single handle: - Side A: Often wide-toothed for detangling or coarse hair. - Side B: Fine-toothed for styling, smoothing, or parting. - Materials: Commonly made of plastic, hard rubber, or occasionally metal/plated metal (imitation jewelry context).

In international trade, classification depends heavily on material composition and function: - If made of plastics/hard rubber → Classified under Chapter 96 (Articles of Hairdressing, Grooming or Cleaning) - If made of base metal (imitation jewelry) → Classified under Chapter 71 (Imitation Jewelry)

⚠️ Key Distinction:
- If the comb is functional hairdressing tool → Chapter 96
- If it is decorative/ornamental (not primarily for hairdressing) → Chapter 71
- Most commercial double-headed combs are classified under Chapter 96 unless explicitly marketed as fashion accessories/jewelry.

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

🔍 Important Note:
- Double-headed combs are primarily hairdressing tools → Chapter 96 is the correct classification.
- Misclassification Risk: If declared as "imitation jewelry" (Chapter 71) when it is functional, customs may reclassify to 9615 and impose penalties.
- Value Threshold: Both 9615.11.10.00 and 9615.19.20.00 require value ≤ $4.50 per gross (144 pieces) to qualify for 0% tax. Exceeding this may lead to different sub-headings (not listed in DATA).

💰 3. 2026 Latest Tariff Rate Breakdown (Including Additional Taxes)

✅ Applicable Country: United States (US)
✅ Origin: China (CN)
✅ Effective Date: 2025–2026 (Current Data)

🎯 1. 9615.11.10.00 – Combs of Hard Rubber or Plastics (Value ≤ $4.50/gross)

📌 Explanation:
- Functional plastic/hard rubber combs are duty-free under this subheading.
- No additional tariffs apply, making this the most cost-effective classification.

🎯 2. 9615.19.20.00 – Other Combs (Non-Plastic, Value ≤ $4.50/gross)

📌 Explanation:
- Combs made of metal, wood, or other materials (non-plastic) also qualify for 0% tax if valued ≤ $4.50/gross.
- Ideal for premium/wooden double-headed combs.

🎯 3. 7117.19.90.00 – Imitation Jewelry (Base Metal)

📌 Explanation:
- Only applicable if the comb is decorative/ornamental (not functional).
- Risk: Customs may challenge classification if the item is clearly a hairdressing tool.

🛠️ 4. Customs Clearance Practical Advice (Avoid Pitfalls)

✅ 1. Required Documentation Checklist

✅ 2. Declaration Tips (Key Principles)

🔥 "Declare Function, Not Just Material! Be Precise!"

📌 Critical Rule:
- Value must be ≤ $4.50 per gross (144 pieces) to qualify for 0% tax under 9615.11.10.00 and 9615.19.20.00.
- Example: If 144 combs cost $700 → $4.86/gross → Does NOT qualify for 0% rate under these subheadings.

✅ 3. Special Cases Handling

🌍 5. Global Market Comparison (2026 Latest)

📌 Conclusion:
- USA offers 0% tariff for double-headed combs under 9615, provided value ≤ $4.50/gross.
- EU, UK, Japan have low but non-zero tariffs.
- Always prioritize Chapter 96 for functional combs to avoid misclassification penalties.

📌 6. Common Errors & Pitfalls (Lessons Learned)

❌ Mistake 1: Declaring a functional comb as "imitation jewelry" (7117.19.90.00)
👉 Consequence: Customs may reclassify to 9615, causing delays, but tax remains 0%. No penalty if corrected early.

❌ Mistake 2: Overstating value as ≤ $4.50/gross when it exceeds
👉 Consequence: Penalties + back taxes if audited. Example: If actual value is $5.00/gross, customs may apply 18.5% (not listed in DATA, but common for other subheadings).

❌ Mistake 3: Misdeclaring plastic combs as "other articles of plastics" (3926.90.99.89)
👉 Consequence: 12.8% tax instead of 0%. Avoid this!

❌ Mistake 4: Not providing product photos/specs
👉 Consequence: Customs may suspect misclassification → Hold goods for inspection.

✅ Correct Approach:

"Double-Headed Hair Comb, Plastic, For Hairdressing Use, Value $4.00/Gross, CPSIA Compliant"

🎯 7. Conclusion: Precise Classification Saves Money!

🎯 Key Takeaways:

🔹 "Functional combs → Chapter 96; Decorative combs → Chapter 71"
🔹 "Value ≤ $4.50/gross → 0% tax; Exceed → Higher tariffs"
🔹 "Always provide specs + photos to avoid delays"

📌 Pro Tip:
- If your double-headed combs are premium/high-value (>$4.50/gross), consider advance ruling from US Customs to determine correct HS Code and avoid surprises.
- For children’s products, ensure CPSIA compliance (lead/phthalate limits) to prevent rejection.

📣 Action Step:

📞 Consult a licensed customs broker + Submit product specs + Verify value per gross
🚀 Clearance secured, costs minimized, profits maximized!

✨ Professional clearance starts with accurate classification!
💼 Every dollar counts—classify right, pay less!