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HQ 955018

January 25, 1994

CLA-2 CO:R:C:M 955018 MBR


TARIFF NO.: 8471.92.70

Mr. John M. Peterson
Neville, Peterson & Williams
39 Broadway
New York, New York 10006

RE: Xerox Corporation; Work Group Color Laser Printer and Starter Kit; NY 854057; NY 877074; Unassembled; Incomplete

Dear Mr. Peterson:

This is in reply to your letter of August 19, 1993, on behalf of Xerox Corporation, requesting the classification of the "Work Group Color Laser Printer" and "Starter Kit" of components therefore, under the Harmonized Tariff Schedule of the United States (HTSUS). The printer and components are manufactured in Japan.


The Work Group Color Laser Printer ("Printer") is designed to print color documents based on digital input from automatic data processing ("ADP") machines. This is a general purpose printer with a resolution of 300 dots per inch ("dpi"). In its imported condition it will include a printer engine and a paper transport mechanism, however, the electronic controller board will be incorporated after importation.

The "Starter Kit" ("Kit") will be imported in its own box within the "master" box which contains the printer. The Kit includes the following items necessary for the printer to operate; 1) toner dispensers (four, each with a different color), 2) developer housings (four), 3) OPC belt cartridge, 4) bottle of fuser oil, 5) cleaning pad, and 6) waste toner box.

After importation, the printer will be removed from the master box, the electronic controller board will be added, and then the printer will be returned to the same master box with its Kit.


What is the classification of the Xerox "Work Group Color Laser Printer" (without controller board) imported with the "Starter Kit," under the Harmonized Tariff Schedule of the United States (HTSUS)?


The General Rules of Interpretation (GRI's) to the HTSUS govern the classification of goods in the tariff schedule. GRI 1 states, in pertinent part:

...classification shall be determined according to the terms of the headings and any relative section or chapter notes...

GRI 2(a) provides the following guidance regarding the classification of incomplete and unassembled goods:

Any reference in a heading to an article shall be taken to include a reference to that article incomplete or unfinished, provided that, as entered, the incomplete or unfinished article has the essential character of the complete or finished articles. It shall also include a reference to that article complete or finished (or falling to be classified as complete or finished by virtue of this rule), entered unassembled or disassembled.

Inasmuch as the printer is missing only the electronic controller board, it retains the essential character of the complete printer. Thus, it is classifiable under subheading 8471.92.70, HTSUS, which provides for other printers. See NY 854057, dated July 10, 1990, and NY 877074, dated August 12, 1992, for similar rulings regarding similar merchandise.

The "Starter Kit" is a group of components necessary for the operation of the printer. The Harmonized Commodity Description and Coding System Explanatory Notes ("ENs") to the HTS, regarding the application of GRI 2(a) to Section XVI, page 1132, state as follows:

(See General Interpretive Rule 2 (a))

For convenience of transport many machines and apparatus are transported in an unassembled state. Although in effect the goods are then a collection of parts, they are classified as being the machine in question and not in any separate heading for parts. The same applies to an incomplete machine (see Part (IV) above), presented unassembled (see also in this connection the General Explanatory Notes to Chapters 84 and 85). However, unassembled components in excess of the number
required for a complete machine or for an incomplete machine having the characteristics of a complete machine, are classified in their own heading.

Therefore, since the starter kit is a collection of components necessary for the operation of the printer, the printer and kit are classifiable together as an incomplete, unassembled printer. There are no excess components in the "Starter Kit."


The Xerox Work Group Color Laser Printer is classifiable in subheading 8471.92.70, HTSUS, which provides for: "[a]utomatic data processing machines and units thereof: [o]ther: [i]put or output units...: [o]ther: [p]rinter units: [o]ther. The rate of duty is Free.


John Durant, Director

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