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NY C86920




April 27, 1998

CLA-2-84:RR:NC:1:110 C86920

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 a Canon BJC-4400 Color Bubble Jet Printer from Japan and Thailand.

Dear Mr. Grace:

In your letter dated April 16, 1998, on behalf of Canon Computer Systems, Inc., you requested a tariff classification ruling.

The merchandise under consideration involves the Canon BJC-4400 Color Bubble Jet (BJ) Printers when they are imported in the same shipping carton as the Color BJ ink cartridges which serve as their printing mechanism. This BJC-4400 Color BJ Printer is designed for use as a computer output unit.

The printer is capable of printing in black and white or color. Three different cartridges may be installed; the BC-21e Color BJ Cartridge, the BC-20 Black BJ Cartridge, and the BC-22e Photo BJ Cartridge. Only one cartridge is installed at any time, and thus the user needs to change cartridges depending on his printing needs.

The BC-21e Color BJ Cartridge incorporates a Bubble Jet print head and two ink tanks. The BCI-21 Color ink tank contains reservoirs for cyan, yellow, and magenta ink. The BCI-21 Black ink tank contains a reservoir for black ink only. The print head for the BC-21e Color BJ cartridge contains a total of 136 nozzles; 64 nozzles for black and 24 nozzles for each of the three colors. When the ink runs out, replacement ink tanks may be installed.

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, the cartridge must be replaced.

The BC-22e Photo BJ Cartridge incorporates a Bubble Jet print head and four reservoirs, containing cyan, yellow, magenta, and black ink. The print head contains a total of 136 nozzles; 64 nozzles for black and 24 nozzles for each of the three colors. When the ink runs out, the cartridge must be replaced.

The three cartridges are designed for use in Canon's BJC printers and have no other uses. 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, no printing can be performed.

Instead of packing a single printer assembly and Color BJ cartridge in a shipping carton, the foreign supplier will pack three partially assembled printers, three Color BJ cartridges (and associated ink tanks), three dedicated AC adapters, and three printer cartridge storage boxes in a single shipping carton. Although the printers and Color BJ cartridges will be shipped in the same carton, the cartridges will be detached from the printer assemblies and enclosed in separate sealed containers.

Following importation, the contents of a shipping carton would typically be repacked into three retail display boxes. A single printer assembly, Color BJ cartridge, dedicated AC adapter, and printer cartridge box would be placed in each retail display box. The Color BJ cartridges will not be installed in the printer until after the unit has been purchased by a retail customer in the United States.

Noting that the Canon BJC-4400 Color Bubble Jet Printer and the Color BJ cartridges are packed separately from the ink jet printers, the printers should be treated as "unassembled units" even though the shipping cartons in question will contain three partially assembled printers, three Color BJ cartridges (and associated ink tanks), three dedicated AC adapters, and three printer cartridge storage boxes. Bubble jet printers shipped in the same shipping 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 Canon BJC-4400 Color Bubble Jet Printer shipped as three partially assembled ink jet printers, three sealed Color BJ cartridges (and associated ink tanks), three dedicated AC adapters, and three printer cartridge storage boxes, which are separated packed in a single 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.

Sincerely,

Robert B. Swierupski
Director,

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