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August 19, 1999

CLA-2-84:RR:NC:1:110 E86023


TARIFF NO.: 8471.60.5400; 8524.39.4000

Ms. Sandra Liss Friedman
Barnes, Richardson & Colburn
475 Park Avenue South
New York, N.Y. 10016

RE: The tariff classification of a multifunction color inkjet machine from Japan.

Dear Ms. Friedman:

In your letter dated August 12, 1999, on behalf of Brother International Corporation, you requested a tariff classification ruling.

The merchandise under consideration involves a Brother model MFC 9100c multifunction machine that can perform printing, copying, scanning, and faxing functions.

The MFC 9100c is capable of performing six separate functions, most of which center on the unit’s color ink-jet print engine. The unit is capable of color printing, monochrome printing, plain paper faxing, color flatbed copying as well as sheet feeder copying, color scanning, and color video capture and printing. The machine will be imported with a standard bi-directional Centronics printerport that can be connected to any IBM-compatible computer with an included printer cable. The machine comes equipped with driver software to allow printing from Windows 3.1, Windows 9x, and Windows NT workstation network software. It will also be imported with a software bundle, including document management, optical character recognition, business template, and image manipulation software recorded on compact discs.

The MFC 9100c is capable of printing in color at up to 1440 x 720 dpi resolution, which is competitive with the latest stand alone color ink-jet printers on the market. The machine can hold up to 250 pages in its paper tray, and can handle up to 50 pages at a time in its document feeder. The print engine prints at a speed of up to 7 ppm in black and white, and 4 ppm in color. In contrast when used as a copier, the MFC 9100c will produce copies at a speed of 3-4 ppm in black and white, and 1.5 ppm in color. The machine incorporates a 14.4k bps fax modem, and scans at up to 1200 x 1200 dpi resolution.

Most of the functions of the MFC9100c are dependent upon the connection of the unit to a PC (networked or standalone) for complete functionality. For example, the scanner and video capture functions depend primarily on software running on a PC to operate. The PC fax function (which allows faxing over the Internet using included “Netcentric” fax software requires a connection to a PC to operate. Although the machine is capable of several different functions, the main functions of the unit are dependent on, and subsidiary to, the print engine.

Noting GRI-3 (b), this machine would met the definition of a composite good, and would thus be classified as if it consisted of the material or component which gives it its essential character, insofar as this criterion is applicable. Noting the machines high print resolution, and the fact that the printing mechanism incorporating the ink-jet engine is used when the product functions as a printer as well as when the product receives faxes and functions as a copier, the “essential character” of this machine would appear to be the printing function. This model also meets the definition of a “unit” of an ADP system, noting both LN 5 (B) and (E) to Chapter 84 of the HTS. The CD-ROM software would be separately classified noting Legal Note 6 to Chapter 85 of the HTS. Please note also HQ ruling 961153 and NY ruling E80009 for similar merchandise.

The applicable subheading for the MFC 9100c multifunction machine will be 8471.60.5400, Harmonized Tariff Schedule of the United States (HTS), which provides for ink jet printer units incorporating at least the media transport, control and print mechanisms. The rate of duty will be free.

The applicable subheading for the CD-ROM software will be 8524.39.4000, HTS, which provides for other recorded media, for reproducing representations of instructions, data, sound, and image, recorded in a machine readable binary form, and capable of being manipulated or providing interactivity to a user, by means of an ADP machine. The rate of duty will be 0.9 percent ad valorem.

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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