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NY 813553

August 11, 1995

CLA-2-90:S:N:N1:110 813553


TARIFF NO.: 9009.12.0000

Mr. Raymond A. Valdes
Ricoh Corporation
5 Dedrick Place
West Caldwell, N.J. 07006

RE: The tariff classification of a multi-functional copier/fax machine from Japan.

Dear Mr. Valdes:

In your letter dated August 8, 1995, you requested a tariff classification ruling.

The merchandise under consideration involves a model Ricoh MV310 multi-functional fax/copier machine. This machine offers copier, facsimile and optional printer, and PC facsimile, plus scanner functions in one compact unit.

In copy mode, the RICOH MV310 operates as an electrostatic photocopying apparatus by reproducing the original image via an intermediate onto the copy (indirect process) producing 10 copies per minute at 400 by 400 dots-per-inch resolution. It provides many digital capabilities as standard features, including automatic reduction and enlargement. It copies at 10 PPM, letter size, and also offers many high end copier features such as center/border erase, automated paper selection, and photo or text copy modes.

In facsimile mode, this composite machine has a platen based design to easily fax bound or oversize originals. It features 9 second transmission speed, 9,600 bps with fallback, 5.6 second quick scan speed, and memory capability. Its multiple resolution scanning gives up to 203 x 391 dpi transmission resolution.

Noting Legal Note 3 to Section XVI of the HTS, this copier/fax machine would meet the definition of a "composite" machine, since it performs two or more complementary functions such as copying and faxing. Since this machine does not appear to have the "essential character" of either a copying or fax machine, it should be classifiable under the heading which occurs last in numerical order among those which equally merit consideration as noted in GRI-3 (c) of the HTS.

The applicable subheading for the Ricoh MV310 copier/fax machine will be 9009.12.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for electrostatic photocopying apparatus, operating by reproducing the original image via an intermediate onto the copy (indirect process). The rate of duty will be 3.7 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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