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NY A 88085

October 4, 1996

CLA-2-84:RR:NC:1:110 A 88085


TARIFF NO.: 8471.80.1000; 8524.91.0030

Mr. John M. Peterson
Neville, Peterson & Williams
80 Broad Street
34th Floor
New York, N.Y. 10004

RE: The tariff classification of an SX 1000 Digital Front End Unit from Israel

Dear Mr. Peterson:

In your letter dated September 23, 1996, on behalf of Xerox Corporation, you requested a tariff classification ruling.

The merchandise under consideration involves a model SX 1000 Digital Front End Controller unit (DFE) that is designed to be used with the "Apex" multifunction printer terminal.

The digital front end unit controller is housed in its own free-standing enclosure and usually used with a keyboard and monitor. They are connected, through the DFE, to Ethernet networks, allowing the DocuColor 40/Apex system to interact with network personal computers, including IBM and Apple-format computers. The DFE also facilitates auto duplex capability and continuous printing. Among its other functions, the controller unit performs a wide range of color management functions,including ColorSync 2.0 profile support, "screen to print" color matching and "print to press" color matching.

The DFE uses a client/server architecture and drives the DocuColor 40 print engine and links the color production system to the network workstation. It incorporates a Motorola Power Pc microprocessor, a power supply, printed wiring board assemblies, and disk drives which are programmed with proprietary software. The PC platform, as indicated by the inquirer, is modified by installing proprietary printed circuit boards, and programming the system with function-dedicated software. Noting Legal Note 5 (A) to Chapter 84, this DFE unit would appear no longer to be a freely programmable digital processing unit. The software that is encoded on the hard disk, is designed to allow the DFE to coordinate the functioning and control of the various units of an ADP system in "real time", so that information can be fed to, and printed from, the Apex/DocuColor 40 printer. The Apex color printer was previously ruled to be an ADP output unit.

The applicable subheading for the SX 1000 DFE controller will be 8471.80.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for control or adapter units. The rate of duty will be free.

The encoded software that is recorded on the hard disk drive of the DFE unit would be separately classifiable, noting in part Legal Note 6 to Chapter 85 of the HTS, and the principles cited in HQ ruling letter 950675 of January 7, 1992.

The applicable subheading for the software will be 8524.91.0030, HTS, which provides for recorded media, prepackaged software for ADP machines, of a kind sold at retail. The rate of duty will be 5.8 cents per square meter of recording surface.

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.


Roger J. Silvestri

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