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:

2 (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

3 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)

4 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.

5 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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