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HQ 958124




March 13, 1996

CLA-2 RR:TC:MM 958124 LTO

CATEGORY: CLASSIFICATION

TARIFF NO.: 8473.30.50

Mr. Donald L. Fisher
Mr. Mark S. Pigram
Deloitte & Touche
50 Fremont Street
San Francisco, California 94105-2230

RE: JetFax M5; Printer/Scanner Assembly; GRI 3(b); HQ 958348; NYs 804946, 811776, 897228; subheadings 8471.60.54, 8471.60.57

Dear Mr. Fisher and Mr. Pigram:

This is in response to your letter of April 28, 1995, to the Area Director of Customs, New York Seaport, requesting, on behalf of JetFax, Inc., the classification of a printer/scanner assembly for the JetFax M5 under the Harmonized Tariff Schedule of the United States (HTSUS). Your letter was referred to this office for a response.

FACTS:

The article in question is a printer/scanner assembly for the JetFax M5 (JetFax). A complete JetFax is a multi-function office machine that can function, when connected to a personal computer (PC), as a light emitting diode (LED) printer, plain paper facsimile machine, PC fax modem, PC scanner and copier. All of these components are integrated in a single housing. The JetFax is connected to a PC through a standard Centronics parallel port for printing and through a serial port for scanning and PC fax transmission. The printer's print speed is four pages per minute.

The printer/scanner assembly, which is used in the performance of the complete JetFax's printing, scanning and facsimile functions, consists of a printer assembly, scan - 2 -
assembly, cabinet assembly and base assembly. The printer assembly contains an I/D unit (EP cartridge), toner cartridge and a 300 dots per inch (dpi) LED head. The printer assembly is imported without a parallel interface, main controller or liquid crystal display (LCD) control panel. The scan assembly contains a 300 dpi sensor and various mechanical parts. The scan assembly is imported without a serial interface, main controller LCD control panel and scanning electronics which send the signal to the processor. The base assembly contains the printer assembly's video driver card and various mechanical parts, while the cabinet assembly consists only of non-computerized mechanical parts. As imported, the printer/scanner assembly cannot function as a printer or scanner.

ISSUE:

Whether the printer/scanner assembly for the JetFax M5 is classifiable under heading 8473, HTSUS, which provides for parts suitable for use solely or principally with the machines of heading 8471, HTSUS.

LAW AND ANALYSIS:

The General Rules of Interpretation (GRI's) to the HTSUS govern the classification of goods in the tariff schedule. GRI 1 states, in pertinent part, that "for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes . . . ."

Recently, this office considered the classification of two integrated printer-copiers, the HP CopyJet and CopyJet M. In HQ 958348, dated January 17, 1996, we determined that the printer-copiers were GRI 3(b) "composite goods," and were, therefore, classifiable as if consisting of the component which gives them their "essential character." We then held that the "printing module," which was used for both the ADP (automatic data processing) output as well as the copying function, imparted the devices' "essential character." For other rulings classifying multi-function printers under heading 8471, HTSUS, see NY 811776, dated June 27, 1995 (Xerox Concorde); NY 804946, dated December 13, 1994 (Xerox Cactus); and NY 897228, dated April 29, 1994 (Xerox HQ310) (though not specified in NY 804946 and NY 897228, classification of these multi-function printers is governed by GRI 3). Accordingly, the HP CopyJet and CopyJet M were classified under subheading 8471.92.44 (now, 8471.60.54), HTSUS, which provides for assembled, ink jet printer units of ADP machines, incorporating at least the media transport, control and print mechanisms. - 3 -

Similarly, it is our opinion that the printing component of the JetFax imparts the device with its essential character. Of the JetFax's four functions, the printer is the least limited. While the print speed has been slowed somewhat (four pages per minute--faster than the Xerox Cactus), the print quality remains the same. The JetFax's remaining functions are more limited--the class 2 fax/modem provides a poorer resolution quality (lower dpi) than the industry standard; the copier is relatively slow, and is therefore, more of a "convenience" copier; the scanner has a lower resolution than the industry standard (300 dpi), and provides a dithered grey scale, rather than a true grey scale (assigns different levels of dots to simulate true grey color/scale); and finally, the copier and scanner are limited by their size (for example, the user cannot copy or scan a book).

It is our opinion that the JetFax, a GRI 3(b) "composite good," is classifiable under subheading 8471.60.57, HTSUS, which provides for other assembled printer units of ADP machines, incorporating at least the media transport, control and print mechanisms. The printer/scanner assembly, a part of the JetFax, is not a "good included" in any chapter 84, 85 or 90 heading. See section XVI, note 1(m), 2(a), HTSUS. Accordingly, the assembly, which is used solely with the JetFax, is classifiable as a part under subheading 8473.30.50, HTSUS, which provides for other parts of ADP units, not incorporating a cathode ray tube. See section XVI, note 2(b), HTSUS.

HOLDING:

The printer/scanner assembly is classifiable under subheading 8473.30.50, HTSUS, which provides for other parts and accessories of the machines of heading 8471, HTSUS, not incorporating a cathode ray tube. The corresponding rate of duty for articles of this subheading is free.

Sincerely,

John Durant, Director

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