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NY C86223

April 13, 1998

CLA-2-84:RR:NC:1:110 C86223


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 when shipped in the same carton as detached printing mechanisms from Japan.

Dear Mr. Grace:

In your letter dated April 2, 1998, on behalf of Canon Latin America, Inc., you requested a tariff classification ruling.

The merchandise under consideration involves the "Canon" BJC-4650 Color Bubble Jet Printers when individual units are imported in the same shipping cartons as BJ ink cartridges which serve as their printing mechanism. This printer is designed for use as a computer output unit.

The BJC-4650 is capable of printing in black and white or color. Three different cartridges may be installed in the BJC-4650; the BC-21e Color BJ Cartridge, the BC-22e Color Photo BJ Cartridge, and the BC-20 Black BJ Cartridge. Only one cartridge is installed at any time. One BC-21e cartridge and one BC-20 cartridge is imported with the printer. Before the BJC-4650 can function as a printer, an ink cartridge containing an ink jet print head must be installed.

The BC-21e Color BJ Cartridge and the BC-22e Color Photo BJ Cartridge incorporate a Bubble Jet print head and four ink reservoirs, containing black, cyan, magenta, and yellow ink. The print head for the BC-21e and the BC22e Color BJ Cartridges contain a total of 136 nozzles for each cartridge; 64 nozzles for black and 24 nozzles for each of the three colors. The BC-20 Black BJ Cartridge incorporates a Bubble Jet print head and a black ink reservoir. The print head contains 128 nozzles. When the ink runs out, replacement ink tanks may be installed for each of these BJ cartridges.

The BC-21e, BC-22e, and the BC-20 cartridges are designed for use in Canon's BJC printers and have no other uses. 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.

Canon Latin America intends to import the printers in an unassembled format. Although the ink cartridges (which contain the print head units) will be imported in the same shipping cartons as the BJC-4650 printers, they will be detached from the printer assembly and enclosed in sealed plastic containers. Thus the BJ ink cartridges will not be installed in the printers at the time of importation. Rather these BJ ink cartridges will be "overpacked" with the printer assemblies, and will not be installed in the printers until after the units have been purchased by retail customers. Bubble Jet printers shipped in the same carton as detached printing mechanisms, and thus not fully assembled units were the subject of NY Ruling Letters C84386 and NY C80114.

The applicable subheading for the BJC-4650 Color Bubble Jet printers shipped as partially assembled ink jet printers, where the print head cartridges are not installed in the printers at the time of importation, but rather are separately packed and imported in the same shipping carton 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.


Robert B. Swierupski

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