The tariff classification of Silverette Nursing Cups from Italy

N355953
December 8, 2025
CLA-2-71:OT:RR:NC:N4:441
CATEGORY: Classification
TARIFF NO.: 7115.90.4000; 9903.02.20
Anna Forlesi Silver Mamas LLC 26601 Brandon Mission Viejo, CA 92692 RE: The tariff classification of Silverette Nursing Cups from Italy Dear Ms. Forlesi: In your letter dated November 12, 2025, you requested a tariff classification ruling. Product information was submitted for our review. The article at issue is a pair of Silverette Nursing Cups. These small, precision-crafted silver nipple protectors designed to be worn by breastfeeding women to help prevent or relive nipple soreness and cracking. The cups are made of pure 925 silver. In your letter, you suggest classification in subheading 9018.90.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other instruments and apparatus used in medical, surgical, dental or veterinary sciences, and parts and accessories thereof. We disagree. You state that the Silverette Nursing Cup's purpose is to protect and soothe breastfeeding mothers’ nipples from soreness and cracking. It is not used by medical professionals to diagnose, prevent or treat an illness, or to operate, etc. Heading 9018 does not apply. The classification of this product has been addressed in N343239 dated October 31, 2024. The applicable subheading for the Silverette Nursing Cups will be 7115.90.4000, HTSUS, which provides for “Other articles of precious metal or of metal clad with precious metal: Other, Other: Of silver, including metal clad with silver. The rate of duty will be 3% ad valorem. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of the European Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15

percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General duty rate. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.02.20, in addition to subheading 7115.90.4000, HTSUS, listed above. 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 at https://hts.usitc.gov/. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Vikki Lazaro at [email protected].
Sincerely,
(for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division