Ms. Cortney O. Morgan
750 17th St. N.W., Suite 900
Washington, DC 20006-4675
RE: The tariff classification of mustache and beard groomers from China
Dear Ms. Morgan:
In your letter dated March 9, 2017, you requested a tariff classification ruling on behalf of Spectrum Brands Holdings, Inc. (“Spectrum Brands”).
The merchandise under consideration is identified as the Remington brand Mustache and Beard
(MB) Groomers. Samples of product numbers MB-20, MB-200, MB-4040, and MB-4015 were submitted with your ruling request and will be returned to you. Based on the samples and information that you have provided, the four products are designed for precise trimming and shaping various mustache and beard styles. They are individually packaged ready for retail sale except for MB-4040 which was in a plain box. You have described the four products as follows:
The Remington MB-20 Stubble & Beard Groomer is a battery operated facial hair groomer with stainless steel, self-sharpening blades with rounded teeth and multiple length settings.
The Remington MB-200 Adjustable Beard Groomer is a battery operated, cordless facial hair groomer with self-sharpening, titanium coated blades and multiple length settings.
The Remington MB-4040 Lithium Power Stubble & Beard Trimmer is a lithium ion battery operated, cordless facial hair trimmer with three (3) types of titanium coated blades (beard, goatee and stubble) and multiple length settings.
The Remington MB-4015 Precision Mustache & Beard Styler is a battery operated, cordless trimmer with T-blade design for high precision facial hair trimming and detailing with an adjustable length comb with three settings.
In your letter you proposed classification for the Remington brand Mustache and Beard (MB) Groomers, product numbers MB-20, MB-200, MB-4040, and MB-4015 under subheading 8510.10.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for shavers, hair clippers and hair-removing appliances, with self-contained electric motor; parts thereof: shavers.
Classification of merchandise under the HTSUS is in accordance with the General Rules of Interpretation (GRIs), taken in order. GRI 1 provides that classification shall be determined according to the terms of the headings and any relative section or chapter notes.
The ENs to heading 8510 states, in pertinent part, the following: This heading covers electric shavers and hair clippers which have a builtin electric motor or vibrator, whether for use on human beings, or for shearing sheep or for grooming horses, clipping cattle, etc. In electric shavers (dry shavers) 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 slots. In the case of hair clippers, a comblike 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. Hair clippers for barbers’ use operate on a similar principle to those for sheep shearers, grooms, etc., but differ in size.
Consideration was given to your proposed classification of the Remington brand Mustache and Beard (MB) Groomers, product numbers: MB-20, MB-200, MB-4040, and MB-4015 under subheading 8510.10.0000, HTSUS. However, these products do not meet the description of the shavers as specified in the ENs to heading 8510. Therefore classification under subheading 8510.10.0000 is not applicable.
The applicable subheading for the Remington brand Mustache and Beard (MB) Groomers, product numbers: MB-20, MB-200, MB-4040, and MB-4015, will be 8510.20.9000, HTSUS, which provides for Shavers, Hair clippers and hair-removing appliances, with self-contained electric motor; parts thereof: Shavers, Hair clippers: Hair clippers to be used for agricultural or horticultural Purposes, Other. The rate of duty will be 4 percent 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 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 Hope Abada at firstname.lastname@example.org.
Steven A. Mack
National Commodity Specialist Division