OT:RR:CTF:EMAIN H351085 DSR
TARIFF NO: 8510.20.90
John A. Schoenig
Grunfeld, Desiderio, Lebowitz,
Silverman & Kledstadt LLP
599 Lexington Ave, Floor 36
New York, NY 10022
RE: Tariff classification of various hair clippers
Dear Mr. Schoenig:
This letter is in reply to your June 25, 2025, request for a binding ruling
concerning the tariff classification of various hair clippers under the Harmonized Tariff
Schedule of the United States (“HTSUS”). Your request was forwarded by the National
Commodity Specialist Division to this office for a response. We have also considered
additional arguments made during a teleconference with my staff on December 18,
2025, and supplemented by an additional written submission. Our response follows.
FACTS:
The products under consideration are referred to as the PALMPERFECT® Full
Body Groomer, (hereinafter “Full Body Groomer”), the “Beautytrim” and the “Bikini
Trimmer.” The Full Body Groomer is of a one-piece design with a rubberized handle to
aid its use in wet conditions. The device’s shaving mechanism is driven by an electric
motor and consists of two reciprocating steel blades that are located on both ends of the
shaving face. The reciprocating blades cut hair by moving back and forth along a stable
metal comb when the device is activated. The product is packaged with two trimming
combs (5 mm and 3 mm) that can be attached to the face of the article to cut longer and
thicker hair and a USB charging cable. The packaging states that the Full Body
Groomer possesses a “curved blade design that ensures a close and precise shave”
and provides for “painless full-body grooming – no nicks, cuts, or irritation.” The product
is recommended for use on legs, underarms, bikini and other sensitive areas.
The Beautytrim is of one-piece design, and its shaving mechanism is driven by
an electric motor and consists of a reciprocating steel blade that cuts hair by moving
back and forth along a stable metal comb when the device is activated. The product is
packaged with a comb attachment for making longer hair length cuts, one AAA alkaline
battery and a covering for the blade when the product is not in use. The packaging
states that the product is safe for use on any part of the body, with extra-fine blades for
use on delicate areas.
The Bikini Trimmer is of a one-piece design, and its shaving mechanism is driven
by an electric motor and consists of two reciprocating steel blades that are located on
both ends of the shaving face. The blades cut hair by moving back and forth along a
stable metal comb when the device is activated. The product’s packaging includes a
comb attachment that can be attached to the face of the shaver to leave longer hair
lengths (if desired). As explained by promotional material, the article is held flat against
the skin to perform a “close” shave.
ISSUE:
Are the articles classified under subheading 8510.10, HTSUS, as shavers, or
under subheading 8510.20, HTSUS, as hair clippers?
LAW AND ANALYSIS:
Merchandise imported into the United States is classified under the HTSUS.
Tariff classification is governed by the principles set forth in the General Rules of
Interpretation (GRIs) and, in the absence of special language or context which requires
otherwise, by the Additional U.S. Rules of Interpretation. The GRIs and the Additional
U.S. Rules of Interpretation are part of the HTSUS and are to be considered statutory
provisions of law for all purposes.
GRI 1 requires that classification be determined first according to the terms of the
headings of the tariff schedule and any relative section or chapter notes. In the event
that the goods cannot be classified solely on the basis of GRI 1, and if the heading and
legal notes do not otherwise require, the remaining GRIs 2 through 6 may then be
applied in order.
The subject devices are imported as retail sets containing components that are
classified in different headings. Those components are the Full Body Groomer, the
Beautytrim, and the “Bikini Trimmer” (heading 8510); the comb attachments for all three
devices and the blade cover for the BeautyTrim (accessories of devices of heading
8510); and the USB charging cable for the Full Body Groomer (heading 8544). Goods
that are prima facie classifiable under two or more headings are classifiable in
accordance with GRI 3, HTSUS. GRI 3 states the following:
When, by application of rule 2(b) or for any other reason, goods are, prima facie,
classifiable under two or more headings, classification shall be effected as
follows:
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(a) The heading which provides the most specific description shall be preferred to
headings providing a more general description. However, when two or more
headings each refer to part only of the materials or substances contained in
mixed or composite goods or to part only of the items in a set put up for retail
sale, those headings are to be regarded as equally specific in relation to those
goods, even if one of them gives a more complete or precise description of the
goods.
(b) Mixtures, composite goods consisting of different materials or made up of
different components, and goods put up in sets for retail sale, which cannot be
classified by reference to 3(a), shall be classified as if they consisted of the
material or component which gives them their essential character, insofar as
this criterion is applicable.
(c) When goods cannot be classified by reference to 3(a) or 3(b), they shall be
classified under the heading which occurs last in numerical order among those
which equally merit consideration.
The included USB charging cable and the comb attachments are accessories of
shavers and clippers of heading 8510, HTSUS. The batteries, if imported alone, would
be classified in heading 8506, HTSUS. None of those articles are involved in the cutting
mechanics of their respective devices. We therefore find that the Full Body Groomer,
the Beautytrim and the Bikini Trimmer provide the essential character of their respective
retail sets, and the sets will be classified accordingly. See GRI 3(b).
At GRI 1, there is no dispute that the subject devices are classified in heading
8510, HTSUS. The issue arises at the six-digit level. Therefore, we begin the analysis
using GRI 6. The issue is whether, at GRI 6, the devices are classifiable as shavers or
clippers. GRI 6, HTSUS, requires that the GRI's be applied at the subheading level on
the understanding that only subheadings at the same level are comparable. The GRI's
apply in the same manner when comparing subheadings within a heading.
The HTSUS headings and subheadings under consideration with regard to the
Full Body Groomer, the Beautytrim and the Bikini Trimmer are as follows:
8510 Shavers, hair clippers and hair-removing appliances, with self-contained
electric motor; parts thereof:
8510.10.00 Shavers…
* * *
8510.20 Hair clippers:
* * *
8510.20.90 Other…
The Harmonized Commodity Description and Coding System Explanatory Notes
(“ENs”) constitute the official interpretation of the Harmonized System at the
international level. While neither legally binding nor dispositive, the ENs provide a
commentary on the scope of each heading of the HTSUS and are generally indicative of
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the proper interpretation of these headings. See T.D. 89-80, 54 Fed. Reg. 35127, 35128
(August 23, 1989).
The terms “clippers” and “shavers” are not defined in the HTSUS. However, the
terms may be construed for tariff classification purposes according to their common and
commercial meanings. See Millennium Lumber Distrib. Ltd., v. United States, 558 F.3d
1326, 1329 (Fed. Cir. 2009). In ascertaining the common and commercial meaning of a
tariff term, CBP “may rely on its own understanding of the term as well as lexicographic
and scientific authorities.” See Lon-Ron Mft. Co. v. United States, 334 F.3d 1304, 1309
(Fed. Cir. 2003).
You present the following dictionary definitions as illustrative of the common and
commercial meanings of “shavers” and “shave”:
A device, especially an electric razor, that is used in shaving. Shaver, American
Heritage Dictionary, https://ahdictionary.com/word/search.html?q=shaver
(last visited October 27, 2025)
To remove the beard or other body hair from, with a razor or shaver. To cut (the
beard, for example) at the surface of the skin with a razor or shaver. Shave,
American Heritage Dictionary,
https://ahdictionary.com/word/search.html?q=shave
(last visited October 27, 2025)
* * * *
An electric device for shaving hair from someone's face or body. Shaver,
Cambridge Dictionary, https://dictionary.cambridge.org/dictionary/english/shaver
(last visited October 25, 27, 2025)
To remove hair from the body, especially a man's face, by cutting it close to the
skin with a razor, so that the skin feels smooth. Shave, Cambridge Dictionary,
https://dictionary.cambridge.org/dictionary/english/shave (last visited October 27,
2025)
* * * *
A tool or machine for shaving; especially: an electric razor. Shaver, Merriam-
Webster Dictionary, https://www.merriam-webster.com/dictionary/shaver (last
visited October 27, 2025)
To sever the hair (from the head or another part of the body) close to the roots.
To cut off (hair or beard) close to the skin. Shave, Merriam-Webster Dictionary,
https://www.merriam-webster.com/dictionary/shave (last visited October 27,
2025)
* * * *
A tool or device that is used to shave hair from your face, body, or head. Shaver,
Britannica Dictionary, https://www.britannica.com/dictionary/shaver (last visited
October 27, 2025)
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To cut the hair, wool, etc., off (someone or something) very close to the skin.
Shave, Britannica Dictionary, https://www.britannica.com/dictionary/shave (last
visited October 27, 2025)
Additionally, you assert that although subheadings 8510.10 (clippers) and
8510.20 (shavers) are eo nomine provisions, use is the determining factor that is of
“paramount importance” in distinguishing between the two competing eo nomine
provisions. See GRK Canada Ltd. v. United States, 761 F. 3d 1354, 1361 (Fed. Cir.
2014); see also GRK Canada, Ltd. V. United States, 180 F. Supp. 3d 1260, 1271 (Ct.
Int’l Trade 2016); aff’d, 885 F. 3d. 1340 (Fed. Cir. 2018). Drawing upon that assertion,
you conclude that the subject devices should be classified as “shavers” of subheading
8510.10.00, HTSUS, because the devices are used in a way that results in what the
cited dictionary meanings subjectively describe as a “close shave.” You conclude that
the ENs are outdated and conflict with the cited dictionary meanings and, therefore, the
cited dictionary meanings should prevail. We disagree.
Eo nomine provisions for shavers and hair clippers cover all forms of such
devices in their condition as imported and without regard to the length of hair that
results from being “shaved” or “clipped.” Whereas the cited dictionary meanings focus
upon the subjective results of “shaving,” i.e., cutting hair “close” to the surface of the
skin, EN 85.10 objectively describes the exact mechanics employed by the devices. EN
85.10 describes a shaver’s function as “rotating or reciprocating cutters or knife blades
slide along the inside of a perforated or slotted plate, thus cutting those hairs which
protrude through the perforations or slot” and describes a clipper’s function as “a
comb-like cutter blade slides to and fro over a fixed metal comb thus cutting the hair or
wool which is caught between the teeth of the combs.”
While you have cited to various dictionaries that merely describe the results
associated with “shavers,” in a prior ruling CBP has cited to a reputable dictionary entry
that aligns with the ENs by describing the distinct, objective cutting mechanism
employed by a “shaver” of heading 8510, HTSUS. See HQ H286686 (September 23,
2019) (citing to the Oxford English Dictionary definition of “shaver” as “A shaving
instrument or tool. Now esp. a small electrical appliance with a set of blades working
against a perforated guard.”). Further, the “uses” of the devices do not diverge, i.e.,
both shavers and clippers are used to cut hair. Moreover, we note that there is nothing
about the term “clippers” that indicates that goods of that provision cannot “clip” hair
close to the skin. The manner by which shavers and clippers operate is the only
relevant distinguishing factor.
Therefore, we are not persuaded by the assertion that EN 85.10 conflicts with the
common and commercial meanings of the terms “clippers” and “shavers.” The tariff
clearly presents clippers and shavers as entirely distinct categories of hair cutting
devices and it would be ill-advised and unworkable for CBP to split hairs by focusing on
an amorphous standard such as “closeness” of shave when examining such devices in
their condition as imported.
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Each of the devices at issuer here cut hair by way of reciprocating cutter blades
that move back and forth over a fixed metal comb. The devices’ cutting actions mirror
the cutting action of a hair clipper described by EN 85.10 and as well as the
aforementioned dictionary definition. We therefore find that the subject
PALMPERFECT® Full Body Groomer, “Beautytrim” and “Bikini Trimmer” are classified
within subheading 8510.20.90, HTSUS, as “other” hair clippers.
HOLDING:
By application of GRIs 1, 3(b), and 6, the PALMPERFECT® Full Body Groomer,
“Beautytrim®” and “Bikini Trimmer” are classified in heading 8510, HTSUS, specifically
in subheading 8510.20.90, HTSUS, which provides for “Shavers, hair clippers and hair-
removing appliances, with self-contained electric motor; parts thereof:
Hair clippers: Other.” The column one, general rate of duty is 4% ad valorem.
This ruling does not address the applicability of any additional duties that may
apply to the goods discussed herein. Likewise, 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 at www.usitc.gov.
Please note that 19 C.F.R. § 177.9(b)(1) provides that “[e]ach ruling letter is
issued on the assumption that all of the information furnished in connection with the
ruling request and incorporated in the ruling letter, either directly, by reference, or by
implication, is accurate and complete in every material respect. The application of a
ruling letter by a Customs Service field office to the transaction to which it is purported
to relate is subject to the verification of the facts incorporated in the ruling letter, a
comparison of the transaction described therein to the actual transaction, and the
satisfaction of any conditions on which the ruling was based.”
A copy of this ruling letter should be attached to the entry documents filed at the
time the goods are entered. If the documents have been filed without a copy, this ruling
should be brought to the attention of the CBP officer handling the transaction.
Sincerely,
Gregory Connor, Chief
Electronics, Machinery, Automotive,
and International Nomenclature Branch
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