Question: If I am toiveling a collection of different keilim, all of which require tevila, am I allowed to place some smaller items inside larger items to make the tevila easier and faster, or is there anything I need to be careful about?
Introduction: The Gemoro in Chagigoh (22a) quotes a Mishna in Mikva’os (6:2) that says that if one places some utensils inside other utensils and tovels them together, the tevila is valid. The Gemoro (ibid) differentiates between two different scenarios:
• In a situation where the outer utensil needs tevila (i.e because it too is tamei) then the tevila also works for the keilim placed inside, irrespective of the size of the opening of the outer kli (as will be discussed).
• In a situation where the outer kli does not require tevila then only if the aperture of the outer kli is the size of “shfoferes hanod” will tevila be effective for the inner keilim.
“Shfoferes hanod” is the width of two fingers and is the default minimum necessary to connect two bodies of water for various mikva’os ramifications.
The Gemoro (ibid) speaks out the reason for this differentiation: When the outer kli does not require tevila, standard mikva’os rules apply and there needs to exist a connection of shfoferes hanod to consider two bodies of water as halachically joined. Therefore, the water in the outer kli is only considered joined to the mikva when there exists the default minimum of shfoferes hanod. If the diameter of the opening of the outer kli is smaller than this amount then the water inside the outer kli is halachically detached from the water of the mikva and thus the inner keilim have not technically been immersed inside a mikva, and tevila for the inner keilim is ineffective.
However, when the outer kli being immersed itself requires tevila, since tevila is effective for the outer kli, the mechanism of “migu” allows tevila to be effective for the inner kli as well. Rashi (ibid d.h. migu) explains that tevila is effective even for a kli with an opening smaller than shfoferes hanod. We are forced therefore to say, that the water inside the kli (even though it is only connected to the mikva with less than shfoferes hanod) can be considered joined regarding the kli itself. And once this water inside the kli can be considered joined regarding the kli itself, it can also can be considered joined regarding the inner keilim.
The Shulchan Aruch (Siman 201 se’if 9) quotes this distinction (regarding keilim temei’im). The Remo (Siman 202 se’if 6) writes that when toiveling keilim inside other keilim, the opening of the outer kli needs to contain the size of shfoferes hanod. The Shach (s.k. 4) explains that this pertains specifically to a situation where the outer kli does not require tevila.
Therefore, in a situation where all keilim being toveled require tevila (e.g. because they are all keilim that were purchased from a non-Jew) one is allowed to tovel keilim inside other keilim, even if the outer kli does not have the size of shfoferes hanod in its opening.
Discussion:
There are however several exceptions to the above rule:
• Metal keilim inside narrow glass keilim – this should be avoided, and will be discussed separately.
• Position of outer kli – the Tosefta (Mikva’os 5:1) also discusses toiveling keilim inside other keilim and differentiates between whether the outer kli is the right way up, or it has been turned on its side. In the former case the tevila is valid; in the latter case a shfoferes hanod for the tevila to be effective. The Rambam learns that this is an additional requirement for tevila to be effective; i.e. besides the requirement that the outer kli needs to be obligated in tevila, in addition the outer kli has to be positioned the right way up (see Beis Yosef Siman 201 [9]).
The Shulchan Aruch (Siman 201 se’if 9) rules this way; that the outer kli needs to be obligated in tevila and has to be positioned the right way up. Therefore, one must ensure that if the aperture of the outer kli is less than shfoferes hanod, it both requires tevila and is positioned in the mikva the right way up.
• Toiveling the outer kli before the inner kli – since it is clear from the Gemoro and Shulchan Aruch that only when the outer kli is obligated in tevila will tevila be effective for the inner kli, it follows that if one toiveled in a way that the outer kli is completely submerged in the mikva before the inner kli; i.e. the inner kli protrudes out of the outer kli since at the time of tevila of the inner kli the outer kli has already had tevila, we can no longer use the migu and tevila will no longer be effective for the inner kli (if the aperture of the outer kli is less than shfoferes hanod).
Conclusion:
• If all keilim being toveled require tevila one is allowed to tovel keilim inside other keilim, even if the outer kli does not have the size of shfoferes hanod in its opening.
• However, one must ensure that the outer kli is positioned the right way up.
• One must also ensure that tevila does not occur to the outer kli before the inner kli.
• If the outer kli does not require tevila and does not contain the size of shfoferes hanod in its opening it is not possible to tovel other keilim inside the outer kli, and if one were to do so the tevila in ineffective and needs to be repeated.
• One should not tovel a metal kli inside a glass kli (if the outer glass kli does not have the size of shfoferes hanod in its opening).