The distinction generally rests on the marking core: pencils have a graphite or similar mineral/composite lead encased in wood or another holder, while crayons are typically solid sticks of wax or oil-bound pigment. Pastels and charcoals are further separated by their binder composition and intended artistic use. Because the boundary can be ambiguous for novelty or combination products, a binding ruling from CBP is advisable before large-volume importation.

Yes — certain pencil products, particularly those originating in China, have historically been subject to antidumping duty orders. Importers should verify the current scope of any active orders with CBP and the International Trade Administration before sourcing, as scope rulings can extend to products that appear distinct from the original petition.