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NY A84115




May 28, 1996

CLA-2-84:RR:NC:MA:110 A84115

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.60.6100

Mr. John M. Peterson
Neville, Peterson & Williams
80 Broad Street, 34th Floor
New York, N.Y. 10004

RE: The tariff classification of a multifunction Color Copier/Printer from Japan.

Dear Mr. Peterson:

In your letter dated May 20, 1996, on behalf of Xerox Corporation, you requested a tariff classification ruling.

The merchandise under consideration involves a "Apex" multifunction Color Copier/Printer terminal. The "Apex" multifunction terminal features an electrostatic laser printing system which is designed to be used as the output unit for automatic data processing (ADP) machines, and especially ADP machines which are networked. In addition to its ADP output function, the Xerox "Apex" incorporates digital copying and scanning capabilities.

In its condition as imported, the Xerox "Apex" incorporates a printer engine together with support system for the ADP laser printing function. These systems include a paper handling guide, a paper drive, a cartridge drive, a cartridge holder, a drive motor for paper transport, a carriage drive motor, and a ribbon cable. The "Apex" features parallel and serial ports which enable connectivity with color servers, such as the Scitex Digital Front End (DFE) unit. Although the primary function of the Xerox "Apex" multifunction device is to perform as a laser printer ADP output unit, it can also be used as a digital copier.

The Xerox "Apex" multifunction Color Copier/Printer terminal appears to be principally imported for use as a color printer for ADP devices and networks. The digital copying function is a subsidiary function which also utilizes the product's laser printing components, subsystems, and functions. The components of this terminal include the printer engine, the printer control, printed wiring board assembly (PWBA), the paper handling systems, the main printed wiring board assembly, and backplane, the power supply, memory wiring board assemblies, operator interfaces and covers. These components account for the majority of the "Apex's" manufacturing costs.

The Xerox "Apex" Color Copier/Printer terminal is a composite good made up of different components which are described under different provisions of the HTS. Although this device is capable of use as a digital photocopier, its principal use appears to be as an output printer for automatic data processing machines. The Xerox "Apex" multifunction device is also similar to the multifunction copier/printer terminal which were the subject of NY Ruling Letters A80061, 817475 and Headquarter's Letter 958348.

Xerox intends to import the "Apex" with the printer toner cartridge removed, packaged separately, and over packed with the device. In its condition as imported therefore, the Xerox "Apex" is not an "assembled" printer as per Heading 8471.60.51.

The applicable subheading for the "Apex" multifunction Color Copier/Printer terminal will be 8471,60.6100, Harmonized Tariff Schedule of the United States (HTS), which provides for other laser printer units capable of producing more than 20 pages per minute. 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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