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NY C83939

February 5, 1998

CLA-2-84:RR:NC:1:110 C83939


TARIFF NO.: 8471.60.6100

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 multifunctional Color Laser Copiers/Printers from Japan.

Dear Mr. Grace:

In your letter dated January 28, 1998, on behalf of Canon U.S.A., you requested a tariff classification ruling.

The merchandise under consideration involves two multifunctional copiers/printers in the CLC series, which are known as the CLC 900 and the CLC 950. Each CLC unit incorporates a Standard Centronic compatible parallel interface port. Using these ports, the CLC copiers/printers may be connected to ADP machines by the use of ColorPASS controllers. These two models in the CLC series are fully capable of operating in a networked computer environment.

The CLC 900 and the CLC 950 provide digital color image quality. They provide digital color output at 400 x 400 dots per inch ("dpi"), with up to 256 graduations per color. Both models are also capable of printing in black and white. The CLC 900 and CLC 950 are capable of printing at the rate of 7 full color pages per minute ("ppm"), or 28 black and white ppm. They are capable of printing on various paper sizes, with a maximum output size of 11 inches by 17 inches.

There are two distinct differences between the CLC 900 and the CLC 950. First, in order to produce two sided output (duplex printing/copying), one must manually feed paper through the CLC 900, thus the operator must re-feed single sided output through the machine to print or copy on the second side. However, the CLC 950 features automatic duplexing. Second, the CLC 900 has two front loading (500 sheet) paper cassettes and a 50 sheet stack bypass. Thus, its maximum paper capacity is 1,050 sheets. The CLC 950 features three front loading (500 sheet) paper cassettes, and a 50 sheet stack bypass. Thus, its maximum paper capacity is 1,550 sheets. The CLC 900 Series functions with Windows 95, Windows NT, and Windows 3.1.

Although the CLC 900 and the CLC 950 may be used as "stand-alone " digital copiers, they appear to be specifically designed for principal use as fast network ADP printers. The digital copying function is a subsidiary function which also utilizes the product's laser printing components.

The CLC 900 and the CLC 950 meet the definition of a "composite good" made up of different components which are described in different provisions of the HTS. The principal use of these multifunctional color laser copier/printers appear to be as networked output printers for ADP systems. These two models of color laser copier/printers are also similar to the multifunction copier/printer devices noted in NY Ruling Letters C81666 and B88291.

Canon U.S.A. intends to import the CLC 900 and the CLC 950 Color Laser Copier/Printers without the toner cartridges. In their condition as imported, these Canon CLC series multi- functional units are not "assembled" printers as per Heading 8471.60.51 and Heading 8471.60.52.

The applicable subheading for the models CLC 900 and the CLC 950 multifunctional Color Laser Copier/Printers will be 8471.60.6100, Harmonized Tariff Schedule of the United States (HTS), which provides for other laser printer units capable of producing more than 20 pages per minute. 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.


Robert B. Swierupski

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