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March 22, 1999

CLA-2-84:RR:NC:1:110 D89153


TARIFF NO.: 8471.60.5500; 8524.99.4000

Ms. Fusae Nara
Winthrop, Stimson, Putnam & Roberts
One Battery Park Plaza
New York, N.Y. 10004-1490

RE: The tariff classification of a multifunctional printer/ copier/facsimile/scanner/PC fax and telephone machine from Japan.

Dear Ms. Nara:

In your letter dated March 11, 1999, on behalf of Sharp Electronics Corporation, you requested a tariff classification ruling.

The merchandise under consideration involves the “Sharp” UX-600M 6-in-1 multifunctional machine which performs printing/ copying/facsimile/scanning/PC fax and telephonic functions. This 6-in 1 multifunctional device operates on thermal transfer technology, and is designed to be used as an output unit within an automatic data processing (ADP) environment.

The Sharp UX-600M multifunctional machine incorporates a thermal print head, consisting of a print head, power supply, main control board, software, and cable connection necessary for use with a personal computer (PC). Model UX-600M is compatible with most “Windows” applications; documents and images can be printed from a PC directly connected to the serial port of this multifunctional device. The UM-600M is imported with ribbon film and is capable of printing two pages per minute when the unit is used as a printer. The resolution of the UX-600M is 200 x 200 dots per inch (dpi) when the unit is used as a printer. The scanner has a resolution of 200 x 400 dpi.

This Sharp UX-600M multifunctional device is also capable of sending and receiving ordinary faxes and can function as a PC fax where a user can send faxes directly from a PC which is connected to it. The UX-600M also incorporates an optical character resolution mechanism, and can function as a scanner. It can also make copies using a document feeder. In addition, the UX-600M can be used as a telephone. This Sharp model UX-600M multifunctional device is therefore advertised as a 6-in-1 multifunctional machine. When this device is used as a fax machine or copier, it uses the same thermal print head that is used when the UX-600M is used as a printer.

The Sharp UX-600M 6-in-1 multifunctional machine meets the definition of a “composite good” (printer, facsimile, scanner, copier, PC fax and telephonic functions) made up of different components which are described in different provisions of the HTS. The printing mechanism incorporating the thermal print head is used when this device receives faxes and functions as a copier and printer. The UX-600M is also imported with ribbon film, and is an assembled unit incorporating at least the media transport, control and print mechanism. Noting GRI-3(b), the “essential character” of this Sharp 6-in-1 multifunctional machine appears to be as a network printer. This device is also similar to the multifunctional printers noted in Headquarter’s Ruling 961153 and NY Ruling B88291.

The applicable subheading for the “Sharp” UX-600M 6-in-1 multifunctional machine will be 8471.60.5500, Harmonized Tariff Schedule of the United States (HTS), which provides for assembled thermal transfer printer units incorporating at least the media transport, control, and print mechanism. The rate of duty will be free.

The software, noting Legal Note 6 to Chapter 85 of the HTS, would be separately classified under HTS number 8524.99.4000 which provides for records, tapes and other recorded media for sound or other similarly recorded phenomena, including matrices and masters for the production of records, but excluding products of chapter 37: other: other. 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 212-637-7019.


Robert B. Swierupski

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