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NY H81239

June 14, 2001

CLA-2-84:RR:NC:1:110 H81239


TARIFF NO.: 8471.60.6400

David R. Grace
Covington & Burling
1201 Pennsylvania Avenue, N.W.
P.O. Box 7566
Washington, D.C. 20044-7566

RE: The tariff classification of the BJC-85 Series Color Bubble Jet Printers from Mexico.

Dear Mr. Grace:

In your letter dated May 24, 2001, you requested a tariff classification ruling on behalf of Canon Business Machines, Inc.

The Canon BJC-85 Series Color Bubble Jet Printers are compact, lightweight, portable printers designed for use with either laptop or desktop computers. They will be imported in the same carton as the BJ ink cartridges, which serve as their print mechanism. The cartridges will not be assembled into the printer, but enclosed in sealed containers. They will not be installed in the printer until after the unit has been purchased by a retail customer in the United States. They are capable of printing in black and color. The BJC-85 is a “dual-head” machine with two separate cartridge slots. Any of three different print head cartridges may be installed in either slot:

The BC-10 Black BJ Cartridge,
The BC-11e Color BJ Cartridge, and/or
The BC-12e Photo BJ Cartridge.

The BC-10 Black BJ Cartridge incorporates a bubble jet print head and a black ink reservoir. The print head contains 128 nozzles. The BC-11e Color BJ Cartridge incorporates a bubble jet print head and two replaceable ink tanks. The print head for the BC-11e Color BJ Cartridge contains 64 nozzles for black ink and 72nozzles for color (24 nozzles for each color). The optional BC-12e Photo BJ Cartridge incorporates a bubble jet print head and an ink reservoir. The print head contains 72 nozzles (24 nozzles for each color). When the ink runs out of these cartridges, the entire cartridge is replaced.

Canon Business Machines, Inc. proposes to ship a detached BC-Black BJ Cartridge and a detached BC-11e Color BJ Cartridge with each BJC-85. In addition, a dedicated power supply will be included in the shipping carton, and a user’s manual. A computer disk with printer driver software may be included in the future. Based on the description of the articles as imported, they would be considered goods put up in sets for retail sale under GRI 3(b). The printer imparts the essential character of these sets.

Nothing Legal Note 6 to Chapter 85 of the Harmonized Tariff Schedule of the United States (HTS), “[r]ecords, tapes and other media of heading 8523 or 8524 remain classified in those headings, whether or not they are entered with the apparatus for which they are intended.” The software in all cases remains separately classified in heading 8524, in accordance with Chapter 85, Note 6, HTS. However, insufficient information has been provided with regard to the computer disk to provide specific classification advice. When additional information is available, you may wish to consider resubmission with regard to the computer disk.

The applicable subheading for the Canon BJC-85 Series Color Bubble Jet Printers, imported with the BJ print head cartridges packed in the same carton, but unassembled into the printer, will be 8471.60.6400, Harmonized Tariff Schedule of the United States (HTS), which provides for “[a]utomatic data processing machines and units thereof[p]rinter units: [o]ther: [i]nk jet.” 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 Eileen S. Kaplan at 212-637-7019.


Robert B. Swierupski

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