Hairbrush Set

🪮 Hairbrush Set (梳妆梳具套装)

🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
📌 I. Product Definition & Classification: Do You Really Understand "Hairbrush Sets"?

A "Hairbrush Set" in international trade is not a single static entity. Its classification depends entirely on its composition, intended use, and specific configuration. It generally falls into two broad categories: Manual Grooming Tools (Chapters 96) or Electric Hair Care Appliances (Chapter 85). Misclassification can lead to massive tariff differences (from 15% to 39%).

⚠️ Key Distinction:
- If it is non-electric (manual combs, brushes, mirrors, scissors): Usually classified under Chapter 96.
- If it includes electric clippers, trimmers, or shavers (even as parts or accessories): Must be classified under Chapter 85.
- Packaging Context: Is it sold as a standalone grooming kit or as part of a larger travel toiletry kit? This changes the HS Code significantly.

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

Based on the provided data, here are the precise HS Codes for Hairbrush Sets, differentiated by purpose and material:

🔍 Critical Reminder:
- Manual vs. Electric: The difference between 9615 (15-21%) and 8510 (39%) is nearly 20-25 percentage points.
- "Set" Definition: If the set contains any electric device (e.g., a hairdryer or clipper), the entire set may be scrutinized under Chapter 85, or the electric component must be declared separately to avoid misclassification penalties.
- Travel Kits: If the hairbrush is bundled with shampoo, toothpaste, etc., in a bag/case, it likely falls under 9605.00.00.00 (Toilette Sets), which has a lower base rate than standalone combs.

💰 III. 2026 Latest Tariff Rate Breakdown (Including Additional Taxes & Policy Surcharges)

✅ Applicable Country: United States (US)
✅ Country of Origin: China (CN)
✅ Effective Date: November 10, 2025 (and subsequent imports)

🎯 1. 9615.19.60.00 —— Hairbrush Sets (Manual, Combing Use)

📌 Explanation:
- The 10% IEEPA tariff is the primary additional cost for Chinese-origin manual grooming sets.
- Unlike electronics or steel, some manual plastic/rubber items may not trigger the 25% Section 301 tariff, resulting in a more manageable 21% total.

🎯 2. 9605.00.00.00 —— Travel Toiletry Sets (Including Hairbrushes)

📌 Note:
- This is the lowest total tariff option (18.1%) among the listed codes.
- Strategy: If your product is a "Travel Kit" (brush + comb + mirror + bag), declare it as a Toiletry Set (9605) rather than separate combs to save 2.9% in taxes.

🎯 3. 9615.11.40.00 —— Hairbrush Sets (Plastic/Hard Rubber)

📌 Note:
- This is the lowest absolute tariff (15.3%) if the item is purely plastic/hard rubber manual brushes.
- Strategy: Ensure the product description clearly states "Plastic Hair Comb" or "Hard Rubber Brush" to qualify for this lower base rate.

🎯 4. 8510.90.40.00 & 8510.20.90.00 —— Electric Hair Clippers/Shavers (Parts or Hosts)

📌 Warning:
- 39% is a HIGH tariff. This is due to the 25% Section 301 additional tariff on Chinese electronics/grooming appliances.
- Do NOT misdeclare electric clippers as "plastic brushes" to avoid this. Customs will require circuit boards, motor samples, or voltage specifications. Misdeclaration leads to fines, seizure, and back taxes.

🛠️ IV. Customs Clearance Practical Advice (Battle-Tested Pitfall Guide)

✅ 1. Documentation Checklist (Essential Items)

✅ 2. Declaration Strategy (Key Mantras)

🔥 "Manual for 15-21%, Electric for 39%, Travel Kit for 18%!"

✅ 3. Special Circumstances Handling

🌍 V. Global Market Comparison (2026 Latest)

📌 Conclusion:
- USA is the most expensive market due to IEEPA (10%) and Section 301 (25% for electric).
- Optimize for Manual/Plastic: If possible, design sets that are manual and plastic-based to enjoy the 15.3% rate.
- Avoid Electric Components: If the target market is the US, avoid including electric clippers/dryers unless you have a clear cost-benefit analysis.

📌 VI. Common Errors & Pitfall Guide (Blood-Tested Lessons)

❌ Error 1: Declaring an Electric Clipper Set as "Hairbrush"
👉 Consequence: Tariff drops from 39% to 15% on paper, but Customs will seize the goods and impose fines for fraud.
✅ Fix: Declare as 8510.20.90.00 and pay the 39%.

❌ Error 2: Bundling a Plastic Comb into a Toiletry Set but declaring only as "Comb"
👉 Consequence: Pay 21% (for 9615.19.60.00) instead of 18.1% (for 9605.00.00.00).
✅ Fix: Declare as "Travelling Toiletry Set" if it contains multiple grooming items in a bag.

❌ Error 3: Ignoring Material Composition
👉 Consequence: Declaring plastic brushes as "Wooden" or vice versa.
✅ Fix: Be precise. "Plastic" qualifies for 9615.11.40.00 (15.3%). "Other Materials" may fall under 9615.19.60.00 (21%).

🎯 VII. Conclusion: Precise Classification, Maximize Profit!

🎯 Remember the Mantra:

🔹 "Manual Plastic = 15.3%, Manual Other = 21%, Travel Set = 18.1%, Electric = 39%!"
🔹 "One Electric Wire = 25% Penalty! Don't Risk It!"

📌 Pro Tip:
If your product is a Hybrid Set (e.g., Manual Comb + Electric Clipper), consult a customs broker for Partial Exemption or Split Shipment strategies. Often, shipping the electric part separately (under 8510) and the manual part (under 9615) is cleaner, but ensure the commercial invoice reflects the actual shipment contents.

📣 Immediate Action:

📞 Contact a Licensed Customs Broker
📄 Provide Product Photos + Material List
🚀 Apply for Advance Ruling if shipping large volumes

✨ Professional Clearance Starts with Accurate Classification!
💼 Your Cost Savings Are Calculated in Every Digit!