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NY 813632




August 18, 1995

CLA-2-84:S:N:N1:110 813632

CATEGORY: CLASSIFICATION

TARIFF NO.: 8473.30.3000

Mr. John Hanson
Epson America, Inc.
20770 Madrona Avenue
Mail Stop B1-02
Torrance, CA 90503-3777

RE: The tariff classification of a Color Upgrade kit (model # C832161) for an inkjet printer from Japan.

Dear Mr. Hanson:

In your letter dated August 14, 1995, you requested a tariff classification ruling.

The merchandise under consideration involves an inkjet printer color upgrade kit that basically consists of a print head assembly and an ink cartridge. The print head will be packaged inside of a storage box.

This kit will be purchased by the consumer, without repacking, when the consumer wants to utilize color printing from their existing monochrome Epson inkjet printer. The consumer would remove the existing ink cartridge and print head assembly and replace them with the color print head assembly and color ink cartridge. The print head assembly is essentially a holder for the ink cartridge and the inkjets themselves. The ink cartridge consists of a water soluble ink, which by itself would be classifiable under HTS heading 3215. The print head, if separately imported would be classified under HTS subheading 8473.30.

Noting GRI-3 (b), this kit appears to meet the definition of a set, since it is put up for retail sale in its imported condition. The essential character of this kit would be exemplified by the print head unit, based on its function, use and value breakdown.

The applicable subheading for the Color upgrade kit will be 8473.30.3000, Harmonized Tariff Schedule of the United States (HTS), which provides for other parts of printers, specified in Additional U.S. Note 2 to this Chapter. The rate of duty will be free.

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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