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NY B87181




July 2, 1997

CLA-2-84:RR:NC:1:110 B87181

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.60.6100; 8471.60.6200

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 Canon GP Digital Imaging Systems from Japan.

Dear Mr. Grace:

In your letter dated June 27, 1997, on behalf of Canon U.S.A., Inc., you requested a tariff classification ruling.

The merchandise under consideration involves three models of Canon GP series of Digital imaging systems; the GP30F; the GP200; and the GP200F. All of these models are multifunctional devices that can perform printing, copying, faxing and scanning functions.

Each model in the GP series is specifically designed to be used as the output unit for an ADP system. With an optional interface board and controller, all three models in the GP series are capable of operating in a Local Area Network (LAN) or client/server workgroup environment. They are also designed to support open industry standards, making it possible to build document management systems that connect directly to multiple computer platforms (e.g., UNIX, Windows, Macintosh).

The Canon model GP30F produces digital black and white output at 400 x 400 dots per inch (dpi), with up to 256 graduations per dot. It weighs 194 pounds, and uses a laser dry electrostatic transfer imaging system. It prints up to 30 pages per minute. All of the three models may be upgraded so as to utilize PCL 5e and Adobe PostScript Level II printing functions, and can be upgraded to include up to 72MB of internal printer memory.

The Canon GP200 and GP200F models produce black and white output at 1200 x 600 dpi resolution and print up to 20 ppm. All of the three models have automatic paper feeders, and a total paper capacity of 1050 sheets. The GP machines are capable of printing on various paper sizes, with a maximum output size of 11" x 17".

The three GP models are all multifunctional machines capable of performing printing, copying, scanning, and faxing functions. The three models are considered to be a composite good made up of different components which are described under different provisions of the HTSUS. Thus, those headings are to be regarded as equally specific under GRI 3(a). Therefore, GRI 3 (a) fails in establishing classification, and GRI 3(b) becomes applicable. The essential character of these GP models of multifunctional machines is exemplified by their printing function. Noting their high print speed, and the fact that these machines appear to be most efficient when networked with an ADP system, the essential character of these machines appears to be for networked document printing functions. Noting Legal Note 5 (B) to Chapter 84 of the HTS, these machines would also meet the definition of a "unit" of an ADP system.

The GP digital multifunctional machines will be shipped without their toner cartridges, and would thus not be considered assembled printer units incorporating at least the media transport, control and print mechanism.

The applicable subheading for the GP30F digital imaging system will be 8471.60.6100, Harmonized Tariff Schedule of the United States (HTS), which provides for other laser printers capable of producing more than 20 pages per minute. The rate of duty will be free.

The applicable subheading for the GP200 and GP200F digital imaging system will be 8471.60.6200, HTS, which provides for other, other, laser 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,

Robert B. Swierupski
Chief, Metals & Machinery Branch

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