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NY A85470





July 17, 1996

CLA-2-84:RR:NC:MA:110 A85470

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.60.6400

Mr. David R. Grace
Covington & Burling
1201 Pennsylvania Avenue, N.W.
P.O. Box 7566
Washington, D.C. 20044-7566

RE: The tariff classification of an ink jet printer without a print head unit from Japan.

Dear Mr. Grace:

In your letter dated July 9, 1996, on behalf of Canon Computer Systems, Inc., you requested a tariff classification ruling.

The merchandise under consideration involves a Canon BJC-240 Bubble Jet Printer that is imported without a print head unit. This BJC-240 Color Bubble Jet Printer is designed for use as a computer output unit, and is capable of printing in black and white or color. Three different cartridges may be installed in the BJC-240; the BC-05 Color BJ Cartridge (standard), the BC-02 Black BJ Cartridge (optional), or the BC-06 Photo BJ Cartridge (optional).

The BC-05 and BC-02 cartridges are designed for use in Canon's BJC-200 printer series and have no other uses. The BC-06 Photo BJ Cartridge is specifically designed for use in the BJC-240 Color Bubble Jet Printer. All three cartridges utilize the same technology. Each nozzle on the print head units contains a heater. When the heater is turned on, ink is vaporized forming an air bubble. As the bubble expands, ink is expelled out of the open end of the chamber. Upon striking the print media, the expelled ink forms a contrasting dot. The selective printing of dots results in the final image. Without a print head unit, no printing can be performed.

CCSI proposes to import the printers in a partially assembled format. Specifically, the print head units will not be installed in the machines. Rather, the printers and ink cartridges (which contain the print head units) will be shipped separately. Noting Legal Note 5(B) of Chapter 84 of the HTS, this printer would meet the definition of a "unit" of an ADP system. Without the print head unit and the ink cartridge, this printer would represent a printer that is without its print mechanism.

The applicable subheading for the Canon BJC-240 Color Bubble Jet Printer when it is imported without a print head unit (print mechanism) will be 8471.60.6400, Harmonized Tariff Schedule of the United States (HTS), which provides for other ink jet printers. The rate of duty will be free.

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

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Art Brodbeck at 212-466-5490.

Sincerely,

Roger J. Silvestri
Director

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