CLA-2-84:OT:RR:NC:N1:102
Koeun Chang
CUSAN Customs Service Incorporation
Number 309, 35 Magokjungang 2-ro, Gangseo-gu
Seoul 07806
South Korea
RE: The tariff classification of breast pump kits from South Korea
Dear Ms. Chang:
In your letter dated September 30, 2025, on behalf of your client, Cimilre Co. Ltd., you requested a tariff
classification ruling. Descriptive information was provided in the submission.
The products under consideration are breast pump kits, models Cimilre S6 Plus, Cimilre Dual Pro, Cimilre
El, Cimilre Motif Luna with battery and Cimilre Motif Aura. The Motif Aura model is comprised of a
wearable breast pump packaged with silicon inserts, a diaphragm, a breast shield, a valve, a bottle, a nipple, a
cap and a USB-C cable. The remainder of the kits are comprised of a main pumping unit packaged with a
breast shield, a valve, upper and lower backflow or diaphragm protectors, a bottle, a nipple, a cap, a power
adapter or a USB-C cable, and an airflow tube. The pumps are configured as diaphragm piston pumps.
The breast pumps kits, which constitute goods classified in two or more headings, are put up in a set ready
for retail sale. Goods that are, prima facie, classifiable under two or more headings, are classifiable in
accordance with General Rule of Interpretation (GRI) 3, Harmonized Tariff Schedule of the United States
(HTSUS). GRI 3(a) states in part, when two or more headings each refer to part only of the materials or
substances contained in mixed or composite goods, those headings are to be regarded as equally specific,
even if one heading gives a more precise description of the good. Goods classifiable under GRI 3(b) are
classified as if they consisted of the material or component which gives them their essential character, which
may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the
role of a constituent material in relation to the use of the article.
In New York Ruling N021593, dated January 24, 2008, CBP classified an electric breast pump packaged
with two breast flanges, two collection bottles, two bottle holders, an AC adapter and tubing within heading
8413, which provides for pumps for liquids. Similar to this ruling, we find the pumps impart the essential
character of their respective kits, as it is the pumps that express milk.
Therefore, in accordance with GRI 3(b), the applicable subheading for the breast pump kits will be
8413.50.0050, HTSUS, which provides for Pumps for liquids, whether or not fitted with a measuring device;
liquid elevators; part thereof: Other reciprocating positive displacement pumps: Diaphragm pumps. The
general rate of duty will be Free.
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 South Korea will
be subject to an additional ad valorem rate of duty of 15 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e., 9903.02.56, in addition to subheading
8413.50.0050, HTSUS, listed above.
The tariffs and additional 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/.
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 Sandra Martinez at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division