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NY 876754

AUG 07 1992

CLA-2-84:S:N:N1:105 876754


TARIFF NO.: 8477.80.0000

Mr. Robert S. Kirschenbaum
V.P. - Administration & General Counsel
Kroy Inc.
P.O. Box C-12279
Scottsdale, AZ 85267-2279

RE: The tariff classification of the Kroy Image Crafter from Japan

Dear Mr. Kirschenbaum:

In your letter dated July 22, 1992 you requested a tariff classification ruling.

The Kroy Image Crafter is a computer-controlled vinyl cutter/plotter and scanner system. Its purpose is to cut vinyl into text, logos and graphics form for the creation of an endless variety of signage and visual commun - ications. Copy is input into an IBM-compatible computer either through the keyboard, a mouse or the scanner included in the Image Crafter package. Output is on colored vinyl sheeting which is backed with white paper. The machine's blade incises the input graphics, text and logos, and when it exits, the user pulls it away from the backing and the excess vinyl before covering it with clear vinyl and imposing it on backing to create signage.

A pen is used in place of the blade for paper check plots. When a plot is satisfactory, the pen is replaced by the cutting blade and the vinyl graphics are cut out. The cutter/plotter is principally used in the cutting mode.

You suggested classification under subheading 8441.10.0000, Harmonized Tariff Schedule of the United States (HTS) which provides for cutting machines for paper. In ruling 851188 this subheading was held applicable to a cutter used to trim and cut drawings which had been produced on a separate electrostatic plotter. The Kroy Image Crafter is not akin to that cutter and therefore, its classification is not the same.

The applicable subheading for the Kroy Image Crafter will be 8477.80.0000, HTS, which provides for machinery for working rubber or plastics or for the manufacture of products from these materials . The rate of duty will be 3.9 percent ad valorem.

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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