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NY 892321




December 8, 1993

CLA-2-90:S:N:N1:110 892321

CATEGORY: CLASSIFICATION

TARIFF NO.: 9009.12.0000

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

RE: The tariff classification of a multi-functional fax/copier/printer from Japan.

Dear Mr. Valdes:

In your letter dated November 19, 1993, you requested a tariff classification ruling.

The merchandise under consideration involves a Ricoh MV715 multi-functional fax/copier/printer. The MV715 incorporates the functions of a high speed laser fax hub, and digital photocopying apparatus, with an optional PC printer interface.

In facsimile mode, the Ricoh MV715 fax/copier/printer is designed as a laser hub for fax networks, and other applications. Its high speed modem transmits documents to other 14.4 kilobytes per second machines, in six seconds per letter-size page, over regular telephone lines. Its 500 sheet paper capacity is supplied by two cassettes holding 250 sheets each accommodating various sizes of paper. The MV715 fax/copier/printer permits users to scan documents into memory while the unit is printing, receiving, or sending documents from memory.

In copy mode, the Ricoh MV715 fax/copier/printer operates as an electrostatic photocopying machine by reproducing the original image via an intermediate onto the copy (indirect process), producing 15 copies per minute at 400 by 400 dots-per-inch resolution. It provides many digital capabilities as standard features, including reduction and enlargement with increments of 25 to 400 percent, directional magnification and series copying.

The Ricoh MV715 fax/copier/printer meets the definition of a "composite" machine as defined in Legal Note 3 of Section XVI of the HTS, since this machine is capable of performing two or more complementary functions such as faxing, copying or printing. Since this machine does not appear to have a principal function, it should be classified under the heading which occurs last in numerical order among those which equally merit consideration as noted in GRI 3(c) of the HTS.

The applicable subheading for the Ricoh MV715 fax/copier/printer will be 9009.12.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for electrostatic photocopying apparatus which operates by reproducing the original image via an intermediate onto the copy (indirect process). The rate of duty will be 3.7 percent ad valorem.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director

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