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NY 873671

MAY 04 1992

CLA-2-84:S:N:N1:105 873671


TARIFF NO.: 8442.20.0000, 8442.40.0000

Mr. Robert S. Kirschenbaum
Kroy Inc.
P.O. Box C-12279
Scottsdale, AZ 85267-2279

RE: The tariff classification of lettering systems and parts from Japan and Taiwan

Dear Mr. Kirschenbaum:

In your letter dated April 16, 1992 you requested a tariff classification ruling.

You inquire about two machines for composing letters, numbers and other symbols: the Duratype 240 and the 360 Digital Lettering System. Your firm will import the model 240 complete from Japan. For the model 360 you will import only printed circuit boards; the rest will be produced in your Wisconsin plant. You also state that you will import replacement parts for the model 240 from Japan.

The 240 and 360 machines compose type and print characters on an adhesive backed strip for transfer to a "paste-up" sheet or other background for generating copy. Both machines include the following five elements: a thermal transfer printing mechanism; a type feed and guide mechanism; software containing font data, font data manipulation printing algorithms and the means to communicate said data to the thermal transfer printing mechanism; color-carrying film and adhesive tape cassettes; and a typewriter-type keyboard. Each model has one built-in typeface. A variety of other typefaces in various sizes are available on data cards. Those cards are installed to a connector via a slot in the printer housing.

When a key on the keyboard is depressed, font data for the selected character is buffered. The 16-character display screen on model 240 and the 80-character one on model 360 allows one to edit before printing. When the desired line of characters has been selected and modified, printing is begun by depressing the print key.

The drive mechanism then propels the color-carrying ribbon and adhesive backed tape past the thermal print head so that the tape and ribbon are in contact and the ribbon's non-color carrying side contacts the print head. As the tape and ribbon move past the print head, the previously buffered data is communicated to the print head, turning heating elements on and off and thus causing transfer of color material to the tape. Model 240 prints up to 15 characters per second at a resolution of 240 dots per inch (dpi), while model 360 prints 26 characters per second at a resolution of 300 dpi.

After each line of composition is printed, the portion of tape bearing it is expelled from the machine and cut. The paper backing is then removed from the adhesive-backed film, which is then positioned on a "paste-up" sheet for layout and photocopying.

The applicable subheading for both the Duratype 240 and the 360 Digital Lettering System will be 8442.20.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for machines, apparatus and equipment for typesetting or composing by other processes, with or without founding device. This provision is free of duty.

Parts of these machines are classifiable in accord with Note 2, Section XVI, HTS. The printed circuit boards for model 360 are not goods included in any of the headings of chapter 84 or 85, and are suitable for use only with model 360. And so, the applicable subheading for them will be 8442.40.0000, HTS, which provides for parts of machinery, apparatus and equipment for type-founding or typesetting. This provision is also free of duty.

Since you do not specify what parts of model 240 you may import, we cannot determine their classifications. Any further inquiry should fully describe them, including their constituent materials.

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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