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NY 805805





January 24, 1995

CLA-2-84:S:N:N1:110 805805

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.92.4400

Mr. William D. Outman, II
Baker & McKenzie
815 Connecticut Avenue, N.W.
Washington, D.C. 20006-4078

RE: The tariff classification of an HP OfficeJet Integrated Printer-Fax-Copier from Singapore.

Dear Mr.Outman:

In your letter dated January 10, 1995, on behalf of Hewlett-Packard Company, you requested a tariff classification ruling.

The merchandise under consideration involves a multifunctional office machine that combines a printer, plain paper facsimile, and a convenience copier in a single unit.

The H-P OfficeJet printer component includes an inkjet printer featuring 600 x 300 DPI resolution; compatibility with the H-P DeskJet 500/510/520 printers; ability to handle different sizes of paper; transparencies and envelopes; and a print speed of up to three pages per minute. This machine uses the same H-P inkjet print mechanism as the H-P Deskjet printer uses. This machine includes a printer driver for Windows and leading MS-DOS applications, and incorporates a Parallel Centronics interface for connection to a personal computer.

The OfficeJet fax component provides the consumer with 65 speed-dial numbers; a 20-page automatic document feeder; a 24- page memory which stores faxes that are received when the machine is out of paper or ink, or when it is printing; and the ability to share a single phone line. In its condition as imported however, the OfficeJet will not have a "line interface unit (LIU)," making it impossible to use the fax. The LIU will be added during final assembly and inspection prior to packaging for sale to users.

The OfficeJet convenience copier component produces up to 99 unattended copies at a rate of 50 seconds per page and has six reduction capabilities (from 100% to 75% in 5% increments).

Although this machine can perform as a fax and as a copier, it appears to be most frequently used as a printer. The machines high DPI resolution and fast printing speed, and the importer's marketing strategy that emphasizes the printer function, leads us to believe that this composite machine will be principally used as an ADP output printer. The copier function is extremely slow and appears to be primarily a convenience feature.

Noting Legal Note 3 to Section 16 of the HTS, this multifunction machine appears to be principally designed and used for printing functions. Note also NY Ruling letter 897228 and 804946 which ruled on similar multifunctional printers.

The applicable subheading for the HP OfficeJet machine will be 8471.92.4400, Harmonized Tariff Schedule of the United States (HTS), which provides for assembled ink jet printers, incorporating at least the media transport, control and print mechanism. The rate of duty will be 3 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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