NY 804130 - The tariff classification of a Color Card Printer from Japan - United States International Trade Commision Rulings

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NY 804130

November 16, 1994

CLA-2-84:S:N:N1:110 804130

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.92.4600

Mr. Christopher E. Pey
Barnes, Richardson & Colburn
475 Park Avenue South
New York, N.Y. 10016

RE: The tariff classification of a Color Card Printer from Japan

Dear Mr. Pey:

In your letter dated November 7, 1994, on behalf of Mitsui & Co., you requested a tariff classification ruling.

The merchandise under consideration involves a card printer, to be sold under the name "NTT Teleca Smart Color Card Printer". This card printer prints information (including color photos) onto plastic and PET cards. The cards printed by the machine are flat and measure 3 3/8" x 2 1/8". The printer uses a thermal transfer printing method with sublimation dye to print in color.

The printer has a built-in color scanner to permit standalone operation without a personal computer but appears to be principally used with personal computers. When used with personal computers, storage and retrieval of information and database management can also be accomplished. In this mode, the printer operates as both an input and output device for a personal computer, which is used to edit the picture scanned by the printer and incorporate data stored on the PC onto the card printed by the machine. The printer is used primarily to print employee identification cards, licenses, certificates and greeting cards.

The printer scans by means of a CCD image sensor, has a scanning area of 108mm x 58mm (max), and can print cards continuously at 40 cards per hour. The printer weighs approximately 38kg, and incorporates a precision built-in color controller. Although capable of operating in a stand-alone mode, the machine in its System 2 and 3 configuration (with personal computer), appears to be the principal use of this printer. Noting Legal Note 5 (B) to Chapter 84 of HTS, this printer would meet the definition of a "unit" of an ADP system.

The applicable subheading for the Color Card Printer will be 8471.92.4600, Harmonized Tariff Schedule of the United States (HTS), which provides for thermal transfer printers, assembled units incorporating at least the media transport, control and print mechanism. The duty rate will be 3.7 percent ad valorem.

Your inquiry does not provide enough information for us to give a classification ruling on the Teleca Card Cleaner. Your request for a classification ruling should include the complete specifications for the cleaning and deburring mechanism. Please provide a sample of a card that requires deburring. Would the lack of this card cleaning have a direct impact on the function of the printer, or are these independent operations?

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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