CBP Ruling N239970 — The tariff classification of a hair cutting comb from China.

Tariff classification

Headings: 8212

GRI rules applied: GRI 3

Product description

You have described the instant item as a hair cutting comb. It consists of a plastic comb on one end and a plastic comb with two embedded double edge steel razors on the other end. You have stated that the item is used to cut hair at home. The hair cutting comb is composed of different components (plastic combs and steel razors) and is therefore considered to be a composite good. The Explanatory Notes to the Harmonized Tariff Schedule of the United States (HTSUS), GRI 3 (b) (VIII), state that the factor which determines essential character will vary between different kinds of goods. It may for example, be determined by the nature of the materials or components, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the goods. When the essential character of a composite good can be determined, the whole product is classified as if it consisted only of the material or component that imparts the essential character to the composite good. In this case we find that steel razor blades impart the essential character to the hair cutting comb.

CBP rationale

The applicable subheading for the hair cutting comb will be 8212.10.0000, HTSUS, which provides for razors and razor blades (including razor blade blanks in strips) and base metal parts thereof: razors.

Full text

N239970 April 12, 2013 CLA-2-82:OT:RR:NC:1:118 CATEGORY: Classification TARIFF NO.: 8212.10.0000 Ms. Martha L. Long LF Accessories Group, LLC 1359 Broadway 21st Floor New York, NY 10018 RE: The tariff classification of a hair cutting comb from China. Dear Ms. Long: In your letter dated March 22, 2013, you requested a tariff classification ruling. You have described the instant item as a hair cutting comb. It consists of a plastic comb on one end and a plastic comb with two embedded double edge steel razors on the other end. You have stated that the item is used to cut hair at home. The hair cutting comb is composed of different components (plastic combs and steel razors) and is therefore considered to be a composite good. The Explanatory Notes to the Harmonized Tariff Schedule of the United States (HTSUS), GRI 3 (b) (VIII), state that the factor which determines essential character will vary between different kinds of goods. It may for example, be determined by the nature of the materials or components, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the goods. When the essential character of a composite good can be determined, the whole product is classified as if it consisted only of the material or component that imparts the essential character to the composite good. In this case we find that steel razor blades impart the essential character to the hair cutting comb. The applicable subheading for the hair cutting comb will be 8212.10.0000, HTSUS, which provides for razors and razor blades (including razor blade blanks in strips) and base metal parts thereof: razors. The rate of duty will be free. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Anthony Grossi at (646) 733-3021. Sincerely, Thomas J. Russo Director National Commodity Specialist Division

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