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NY N009986

May 18, 2007



TARIFF NO.: 8443.99.5010

Mr. Jose Bonilla
Canon USA, Inc.
One Canon Plaza
Lake Success, NY 11042

RE: The tariff classification of a fax board for a multifunction printer/copier/fax machine from Japan

Dear Mr. Bonilla:

In your letter dated April 18, 2007 you requested a tariff classification ruling. You included descriptive literature with your request.

The merchandise at issue is the Super G3 FAX Board for the imageRUNNER multifunction printer model C6870I/C5870U. This unit is a multifunction unit capable of copying, printing, scanning and faxing. Product information for this unit was included with your request. The G3 is a fax board that serves as an optional add-on the enables the imageRUNNER to perform fax functions. You state that the G3 is specifically designed for use with the imageRUNNER and is imported separately from it. Product information for the G3 included with your request specifies that he G3 uses a telephone line on a Public Switched Telephone Network, has one facsimile network line, has multiple scan line density settings, has a transmission speed of up to 33.6 kbps, has an image memory of approximately 5000 pages and an address book of 1800 destinations. You note in your correspondence that beginning with the 2007 Harmonized Tariff Schedule of the United States (HTSUS) both the multifunction printer unit and its dedicated fax board migrated to heading 8443 from other provisions within the tariff. You are correct in this assertion. Multifunction machines which perform two or more of the functions of printing, copying or facsimile transmission and which are capable of connecting to an automatic data processing machine or to a network, as is the case with the imageRUNNER, are classifiable in subheading 8443.31.0000, HTSUS. By operation of General Rule of Interpretation 1 and Section XVI Note 2 (b), the G3 fax board falls to be classified as a part of the imageRUNNER in heading 8443. As you state in your letter, this conclusion is supported by the Explanatory Notes.

The applicable subheading for the G35 fax board will be 8443.99.5010, HTSUS, which provides for parts for the goods of subheading 8443.31. The rate of duty will be free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Patrick Wholey at 646-733-3013.


Robert B. Swierupski

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