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NY 861221

Mar 21 1991

CLA-2-84:S:N:N1:110 861221


TARIFF NO.: 8471.99.1500; 8473.30.4000; 8537.10.0070; 8542.11.0026

Mr. Dennis Heck
Ernst & Young
515 South Flower Street
Los Angeles, California 90071

RE: The tariff classification of Multifunction peripheral controllers and accessories from Hong Kong.

Dear Mr. Heck:

In your letter dated March 6, 1991, on behalf of Elite High Technology, Inc., you requested a tariff classification ruling.

The merchandise under consideration, such as the TRI/O T1000 and T500 controllers are external and internal systems designed to integrate general office functions such as printing, copying, scanning and faxing into IBM PC/laser printing systems. The TRI/O integrates common computer peripherals by creating an all digital office solution.

The TRI/O T1000 (Multifunction peripheral controller) is a standalone unit which incorporates its own 80286 microprocessor and 40MB hard disk drive to store all documents and to enable spooling without monopolizing the user's computer time and disk space. This unit is connected directly to the host computer via a standard 25-pin parallel printer cable. It incorporates the following components: T500 multifunction control board; main board; I/O board; 40MB hard disk drive; power supply; control panel, and jet print cartridge. By connecting this unit to an IBM compatible computer, a laser printer and a scanner, this unit creates a shareable printer, convenience copier, a fax machine, a digital image scanner, and a modem. The laser printer is the output device where normal printing from computer applications will be spooled and printed, where copies are made from the scanner, and where incoming faxes can be printed on a plain paper medium. This controller appears to function primarily as an interconnection device between computers and peripheral devices such as printers and scanners.

The T500 is an internal, plug-in multifunction control board (identical board that is contained in the T1000 MPC) that utilizes the microprocessor and hard disk drive of the user's computer, but otherwise delivers functions similar to the T1000.

The Jet Print Cartridge is a laser print accelerator that allows image data sent from the PC, scanner or incoming faxes to be printed on a laser printer at near printer engine speeds. This device consists of an interface board which plugs into the laser printer and a cable which plugs into the multifunction control board. This device can be imported separately or with the T-1000.

The Control Panel is principally a control device that consists of a keypad and eightline LCD display which controls multiple functions from one desktop control panel. This unit is connected directly to the T500 control board both when it is internally installed in the user's computer or when it is used with the T1000 (that contains the T500 board). This control panel runs on +5 volts DC, and can be imported with the T1000 or separately.

The 1 MB RAM Image buffer expansion kit consists of two individual "unmounted" 1 Meg x 4 bit Dynamic RAMs that expand the image buffer from the 8.5" x 11" standard to legal or B4 size paper. The RAMs are inserted into the empty sockets on the T500 control board.

The applicable subheading for the T1000 multifunction peripheral controller, jet print cartridge, and control panel, when imported together, will be 8471.99.1500, Harmonized Tariff Schedule of the United States (HTS), which provides for control or adapter units. The rate of duty will be free.

The applicable subheading for the T500 multifunction controller board will be 8471.99.1500, HTS, which provides for control or adapter units. The rate of duty will be free.

The applicable subheading for the Jet Print Cartridge when imported separately, will be 8473.30.4000, HTS, which provides for parts and accessories of the machines of heading 8471, not incorporating a cathode ray tube. The rate of duty will be free.

The applicable subheading for the Control panel when imported separately, will be 8537.10.0070, HTS, which provides for boards, panels, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity, for a voltage not exceeding 1,000 Volts. The rate of duty will be 5.3 percent ad valorem.

The applicable subheading for the 1MB RAM Image Buffer Expansion Kit will be 8542.11.0026, HTS, which provides for monolithic integrated circuits. The rate of duty will be free.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director

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