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March 19, 1999

CLA-2-84:RR:NC:1:110 D89195


TARIFF NO.: 8471.60.5200

Mr. Raymond A. Valdes
Ricoh Corporation
Five Dedrick Place
West Caldwell, N.J. 07006

RE: The tariff classification of a multifunctional printing/ copying/scanning/faxing and PC faxing unit from Japan.

Dear Mr. Valdes:

In your letter dated March 9, 1999, you requested a tariff classification ruling.

The merchandise under consideration involves a multi- functional printing/copying/scanning/faxing and PC faxing unit which is known as the Ricoh Aficio FX-10. This multifunctional imaging machine can be connected to a computer via a standard parallel IEEE 1284B cable which enables the unit to print. This device is principally used in a small office or home based business environment.

The Ricoh Aficio FX-10 is a personal multifunctional unit which offers printer/copier/scanner/facsimile, and PC fax modem capabilities. It also incorporates a telephone head set. The Aficio FX-10 has a 10 page per minute print speed, 300 dpi plus resolution enhancement laser output quality, and it contains Microsoft Windows 3.1 , and Windows 95 drivers. GDI printing differs from PCL printing in that it has no print controller or printer memory. Rather, the host PC processes the image data and sends the completed image to the printer. The included printer drivers has other advanced features, such as manual duplexing, printing two or four pages into one page, scaling from 10% to 500% of its original size, and has reverse order printing.

The Aficio FX-10 provides TWAIN complaint 400 dpi (optical) scanning capability for OCR or image capturing applications, plus it offers three scan modes (line-art dither and error diffusion), five brightness levels, plus auto density, and 200 or 400 dpi scan resolutions. The plain paper fax feature set includes 14.4 kbapbs modem with a six second transmission speed, full dual access, 2.4 second quick scan and 18 page fax memory expandable to 354 pages. This unit also has a send/receive PC faxing capability. The Aficio FX-10 weighs 33 pounds, and measures approximately 19.2 x 18 x 9.1 inches. This multifunctional device is capable of performing printing/copying and facsimile functions, and is incorporated within a common housing. Thus, the Aficio FX-10 meets the definition of a composite good made up of different components which are described under different provisions of the HTS. Noting GRI-3(b) to the HTS, this composite good would be classified as if it consisted of the material or component which gives it its “essential character”. Noting that the Aficio FX-10 is most efficient as a networked printer, it would therefore appear to have the “essential character” of a networked automatic data processing machine document printer.

The Aficio FX-10 is also similar to other multifunctional printer/copier/fax machines which were the subject of NY Rulings D83998 and D82304. This model also meets the definition of a “unit” of an ADP system, as per Legal Note 5(B) to Chapter 84 of the HTS.

The applicable subheading for the Ricoh Aficio FX-10 multifunctional printing/copying/scanning/faxing and PC faxing unit will be 8471.60.5200, Harmonized Tariff Schedule of the United States (HTS), which provides for other laser printer units. 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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