RE: The tariff classification of silver paste from Taiwan

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364053 August 26, 2026 CLA-2-71:OT:RR:NC:N4:441 CATEGORY: Classification TARIFF NO.: 7115.90.4000 Cameron Hsu Certone Heat Solutions Inc. 1205 W. Carrier Pkwy Suite 203 Grand Prairie, TX 75050 RE: The tariff classification of silver paste from Taiwan Dear Ms. Hsu: In your letter dated August 5, 2026, you requested a tariff classification ruling. You have submitted product information and descriptions. The product at issue is conductive silver paste. You have indicated in your letter that is it solar/electronic grade. You have provided the following quantity & cost breakdown: U.S. Silver Powder (Ag): <90% weight, 95% cost Glass Powder/Frit: <3% weight, 2% cost (Taiwan) polymer in solvent <8% weight, 0.5% cost (Taiwan) Organic Additives: <1 weight, 0.5% cost (Taiwan) processing fee: 2% cost. Manufacturing Process: Pure United States-origin silver powder will be exported to Taiwan. In Taiwan, the silver powder will be combined with binders/additives via mechanical mixing and dispersion to create silver paste. After reimportation into the United States, the silver paste is screen-printed and thermal cured onto electronic/solar substrates in the U.S. Chapter 71 of the Harmonized Tariff Schedule of the United States (HTSUS), provides in pertinent part at Legal Note 1, Subject to note 1 (a) of section VI and except as provided below (additional exclusion to Chapter 71), all articles consisting wholly or partly of precious metal or metal clad with precious metal are to be classified in this chapter. Upon review of Legal Note 1 (a) of section VI, HTSUS, and Legal Note 3 to Chapter 71, HTSUS, we find no exclusion of the merchandise concerned from Chapter 71, HTSUS.
Further review of the legal notes to Chapter 71, Legal Note 5, HTSUS, indicates: For the purposes of this chapter, any alloy (including a sintered mixture and an inter-metallic compound) containing precious metal is to be treated as an alloy of precious metal if any one precious metal constitutes as much as 2 percent, by weight, of the alloy. Alloys of precious metal are to be classified according to the following rules: (a) An alloy containing 2 percent or more, by weight, of platinum is to be treated as an alloy of platinum; (b) An alloy containing 2 percent or more, by weight, of gold but not platinum, or less than 2 percent, by weight, of platinum, is to be treated as an alloy of gold; (c) Other alloys containing 2 percent or more, by weight, of silver are to be treated as alloys of silver. Please see Headquarters rulings HQ 961499 dated November 23, 1999 and HQ 963178 dated November 23, 1999. The applicable subheading for the silver paste is 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 general rate of duty will be 3% ad valorem. The duties cited above are current as of this ruling’s issuance. 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/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. Eligibility under Subheading 9802.00.6000 You inquired about the applicability of subheading 9802.00.6000, HTSUS, to the above-described silver paste. Subheading 9802.00.6000, HTSUS, provides a partial duty exemption for: [a]ny article of metal . . . manufactured in the United States or subject to a process of manufacture in the United States, if exported for further processing, and if the exported article as processed outside the United States, or the article which results from the processing outside the United States, is returned for the United States for further processing. In order for merchandise to qualify under subheading 9802.00.6000, HTSUS, four requirements must be met: (1) the merchandise must be an article of metal; (2) the metal must either be manufactured in the United States or subject to a process of manufacture in the United States; (3) the metal must be exported for further processing; and (4) the metal must be returned to the United States for further processing.
For purposes of subheading 9802.00.6000, the term “metal” covers (1) the base metals enumerated in note 3 to section XV; (2) arsenic, barium, boron, calcium, mercury, selenium, silicon, strontium, tellurium, thorium, uranium and the rare-earth elements; and (3) alloys of any of the foregoing. Silver is not a covered metal for the purpose of subheading 9802.00.60. As such the first requirement is not met. Having failed the first requirement, the silver paste has not met all four prerequisites and it is not eligible for special tariff treatment under subheading 9802.00.6000. 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) James P. Forkan Director National Commodity Specialist Division