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HQ 087102

August 8, 1990

CLA-2 CO:R:C:G 087102 CMS


Mr. William R. Wilson
Manager, Customs Operations
Centralized Logistics Organization
Xerox Corporation
800 Phillips Rd., Bldg. 0205-99P
Webster, NY 14580

RE: Classification Of "Kits" For Photocopiers And Laser Printers

Dear Mr. Wilson,

Your correspondence dated April 18, 1990, requesting a classification ruling on certain "kits" for photocopiers and printers has been referred by the Regional Commissioner of Customs, New York to Customs Headquarters for a reply.

The merchandise is described as "kits" used in the installation, upgrade and repair of photocopiers and laser printers. No descriptions are provided for any of the articles which make up the "kits".

The Office Of Regulations And Rulings will cooperate in any way possible to issue classification rulings on products which are adequately described. However, it is impossible for Customs to determine whether articles are classified as parts, accessories, sets or eo nomine goods when no specific article descriptions are provided. CR 177.2(b)(2)(ii)(A) provides that "...the request for a ruling should include a full and complete description of the article...".

You state that it would be unfeasible to request rulings on every kit because there are thousands of different kits. Although we appreciate your problem, it would be inappropriate for us to adopt your proposed solution inasmuch as there is no basis for it either in law or in the Customs regulations. One possible approach would be for Xerox to request rulings on a small number of kits representative of the merchandise you import which, with discretion, could then be applied to similar kits.

Although no ruling can be issued in response to your April 18, 1990 request as submitted, the Office Of Regulations And Rulings will of course issue a ruling when adequate descriptions of the articles which make up the "kits" have been provided.


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