Kathy Trotta
Administrative Assistant
Conair Corporation
150 Milford Road
East Windsor, NJ 08250

RE: The tariff classification of wave clips from China.

Dear Ms. Trotta:

In your letter dated June 14, 2010, you requested a tariff classification ruling. As requested, the sample provided will be returned you.

Model # 66610, is a Conair, twelve pack set of wave clips. A photograph of the Conair, Wave Clips, indicates that the item is marketed in a see through clear plastic package, with a header card that states: “Want Curls? wave clips, soft natural waves.” Descriptive literature indicates that the wave clips are individually applied in a three step process: (1) apply setting lotion or gel to damp hair; (2) open the wave clip and slide clip over hair and lock the clip – leave the clip in the hair until completely dry; and (3) remove the clip once hair is dry, and finish by finger combing using mist from hair spray.

The applicable subheading for the wave clips, used to add waves and curls to hair, will be 9615.90.2000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Combs, hair-slides and the like; hair pins, curling pins, curling grips, hair-curlers and the like, other than those of heading 8516, and parts thereof: Other: Nonthermic, nonornamental devices for curling the hair.” The rate of duty will be 8.1% ad valorem.

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

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 Neil H. Levy at (646) 733-3036.


Robert B. Swierupski
National Commodity Specialist Division