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NY I86077

September 23, 2002

CLA-2-84:RR:NC:1:110 I86077


TARIFF NO.: 8472.90.8000

Mr. Joseph L. De La Luz
Customs Compliance Manager
NEC America, Inc.
6555 North State Highway 161
Irving, TX 75039-2402

RE: The tariff classification of a digital multifunction machine from China.

Dear Mr. De La Luz:

In your letter dated August 29, 2002 you requested a tariff classification ruling on behalf or NEC America, Inc.

The merchandise under consideration is a desktop size digital multifunction machine, Model NEC IT3510. Descriptive literature was submitted with your request. In its imported condition, the NEC IT3510 is an unfinished walk up digital copier with fax capability. As per your letter the machine comes standard with one of two document feeders that are dealer supplied in the United States. The document feeders provide both platen and automatic document feeding and are required for the operation of the machine. The product’s standard package consists of the following:

Digital Copier (Copy print speed – 600 x 600 dpi) Letter – 35 cpm
Legal – 23 cpm
Ledger – 19 cpm
First copy time – 4.5 seconds
Duty cycle – up to 150K images/month

Scanner (600 x 600 dpi)
Includes photo, text, and photo and text modes Includes the Automatic Document Feeder (ADF) or the Automatic Document Feeder Reversing (ADFR).

Super G3 33.6 Kpbs with JBIG coding (V.34 + V.8)

Paper Supply/Handling
Cassette 1 – 275 sheet multi-purpose – up to ledger size Cassette 2 – 550 sheet fixed universal – up to ledger size Rotation – Automatic image rotation offers document collation and stacking Tray – By-pass feed tray
Output tray – 500 sheet

Memory – Standard – 32 MB

Weight – 132 lbs. (base model)

A variety of upgrade options are offered with the NEC IT3510: network printing, network faxing, fax to e-mail, IP scanning, IP faxing, various finishing options, etc. With the addition of the Centronics interface option, it becomes capable of operating as a network printer.

The print option (600 x 600 dpi, Centronics Interface) includes: PCL6 – Windows 95/98, 2000, NT4.0
PostScript 3 – Windows 95/98, 2000, NT4.0 Memory – 16 MB standard up to 144 MB maximum 2.5 GB hard drive for PostScript
Network Protocols – TCP/IP, IPX/SPX
Network Interface Card – 10/100 Base T

It is noted that the NEC IT3510 does not contain a telephone handset. As per the literature, the NEC IT3510, as imported, appears to be based on a digital copier design. Under GRI 2 (a), “Any reference in a heading to an article shall be taken to include a reference to that article incomplete or unfinished, provided that, as entered, the incomplete or unfinished article has the essential character of the complete or finished article.” The NEC IT3510, which is only missing the document feeder, is found to have the essential character of a digital copier/fax machine. Two functions come standard in the NEC IT3510: digital copying and faxing. Noting Section XVI, Note 3, the principal function of this multifunction machine appears to be that of the digital copier.

The applicable subheading for the NEC IT3510, imported without a document feeder, will be 8472.90.8000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Other office machinesOther: Printing machines other than those of heading 8443 or 8471.” 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 646-733-3016.


Robert B. Swierupski

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