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NY A81130




March 13, 1996

CLA-2-84:RR:NC:MA:110 A81130

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.60.6400

Mr. David R. Grace
Covington & Burling
1201 Pennsylvania Avenue N.W.
P.O. Box 7566
Washington, D.C. 20044-7566

RE: The tariff classification of multifunctional inkjet printers from Japan.

Dear Mr. Grace:

In your letter dated March 6, 1996, on behalf of Canon Computer Systems, you requested a tariff classification ruling.

The merchandise under consideration involves two models of "Canon Convertible" multifunctional ink jet printers. These printers will be imported without print head units. The printers are known as the "Canon MultiPASS 800" and the "Canon MultiPASS C2500". They are designed for use as computer output units.

The "Canon MultiPASS 800" uses the BX-3 ink jet cartridge which incorporates a bubble jet print head and a black ink reservoir. Due to its capacity for bi-directional printing, the print speed of the "MultiPASS 800" is 2.7 pages per minute. The "MultiPASS 800" has an automatic paper feeder with a 100-sheet paper tray capacity. It incorporates an 8-bit bi-directional parallel interface and a print driver that allows the customer to use the "MultiPASS 800" as the default printer. This printer will be imported in a partially assembled format, that is the print head units will not be installed in the machines. Without the print head unit, no printing can be performed. In addition to being used as an output device for personal computers, the "MultiPASS 800" can send and receive plain paper facsimiles. It also employs the capacity to fax a document directly from a personal computer ("PC") without printing hard copies. The "MultiPASS 800" also incorporates a scanner. Using "contact image" technology, graphics, logos, and printed documents can be scanned into a PC at 200 X 200 bpi. Finally, the "MultiPASS 800" has a convenience copier component that produces up to 99 unattended copies.

The "Canon MultiPASS C2500" is an enhanced color bubble jet printer which can use two different cartridges, the BJ-20 Black BJ Cartridge or the BJ-21 Color BJ Cartridge. The BJ-20 Black BJ Cartridge incorporates a bubble jet print head and a black ink reservoir. The BJ-21 Color BJ Cartridge incorporates a bubble jet print head, a black ink tank, and a color ink tank, containing three ink reservoirs--cyan, magenta, and yellow ink. The "MultiPASS C2500" has a print speed of approximately 5 pages per minute using the BJ-20 Black BJ Cartridge, and approximately 0.8 pages per minute when printing in color. The "MultiPASS C2500" has an automatic paper feeder which has a 150 paper tray capacity. This printer incorporates a IEEE 1284 compatible parallel interface and a print driver that allows the customer to use it as the default printer. The "MultiPASS C2500" Printer will be imported in a partially assembled format. Specifically, the print head units will not be installed in the machines. In addition to being used an output device for personal computers, the MultiPASS C2500 can send and receive plain paper facsimiles. It also has the capacity to fax a document directly from a PC without printing out a hard copy. Additionally, the "MultiPASS C2500" incorporates a scanner, and a convenience copier component that produces up to 99 copies of a single sheet.

The "MultiPASS 800 and the MultiPASS C2500" multifunctional bubble jet printers are component machines that appear to have the "essential character" of a printer, noting GRI-3(b). It is noted that similar multifunctional printers were the subject of various NY Ruling Letters including NY 812318, NY 811776 and NY 805805. The "MultiPASS 800 and the MultiPASS C2500" also meet the definition of a "unit" of an ADP machine system, as noted in Legal Note 5(B) of Chapter 84, HTS.

The applicable subheading for the "MultiPASS 800 and the MultiPASS C2500" multifunctional bubble jet printers will be 8471.60.6400, Harmonized Tariff Schedule of the United States (HTS), which provides for other ink jet printers. The rate of duty will be free.

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

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Art Brodbeck at 212-466-5490.

Sincerely,

Roger J. Silvestri
Director

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