H351085

H351085 March 30, 2026 OT:RR:CTF:EMAIN H351085 DSR CATEGORY: Classification 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 

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