10 stars for being a concept
I understand that you did not want to use a reference and I think this worked out well. Something about both, her nose and perspective of her right eye seem 'off' but they were executed nicely. The lighting / shadows look good over all except maybe inside of the ear.
The hair looks awesome, the only thing I would say is the chopsticks in her hair could use some more detail, but it's fine either way.