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NY B84344




April 16, 1997

CLA-2-84:RR:NC:1:110 B84344

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.60.5200; 8471.60.6200

Mr. Raymond Valdes
Ricoh Corporation
Five Dedrick Place
West Caldwell, N.J. 07006

RE: The tariff classification of multifunction printer/copier/scanner units from Japan.

Dear Mr. Valdes:

In your letter dated April 9, 1997, you requested a tariff classification ruling.

The merchandise under consideration involves the Ricoh Aficio Color 2000, 5000, and NC Series of Digital Color Copier/Printer/Scanner units. The Ricoh Aficio Color Series 2003, 2103, 2203, 5106, 5206, and NC8115 are multifunction digital color copier/printer and scanner print servers. These units in their configuration connected to a Fiery XJ Color server allows these devices to act as printer on a network supporting multiple computer platforms. These platforms include personal computers, Mac, and Unix workstations such as Silicon Graphics and Sun Sparc workstations.

These engines are Raster Output devices which are capable of scanning hardcopy originals to create a master or "Digital Original". These digital originals can then reproduce through its electrophotographic process (laser print engine) to produce full color or black and white prints.

The Ricoh Aficio Color Series 2000, 5000, and NC8115 are all multifunction devices that consist of a single unit which incorporate electrostatic photocopying and laser automatic data processing (ADP) output function. The laser printer and photocopying functions share a single electrostatic imaging system which produces images by adhering color toners to plain paper by means of a photoconductor drum.

The Ricoh Aficio Color Series 2000, 5000, also feature digital scanning, which is used in connection with document production and document creation. The scanner serves as an input device allowing document images to be scanned electronically. The digital file can be sent electronically through most networks allowing multiple users to print their files both color and black and white from any designated Aficio color print engine.

The Ricoh Aficio Color Series 2003, 2103, 2203, 5106, 5206, and NC8115 all meet the definition of a composite good made up of different components which are described in different provisions of the HTS. It is noted that similar multifunctional printers were the subject of various NY Ruling Letters, and recently were the subject of NY A81130 and NY A88887. These multifunction printer units also meet the definition of a "unit" of an ADP machine system as noted in Legal Note 5(B) of Chapter 84, HTS. Although these models are capable of use as digital photocopiers, their principal use appear to be as digital ADP output printers.

The Ricoh Aficio Color 5000 Series color copies print up to 31 pages per minute in black and white or 6 prints per minute in color. The Ricoh Aficio Color 2000 Series prints up to 21 prints per minute in black and white or up to 3 prints per minute in color. The NC8115 prints up to 15 pages per minute in both black and white and full color.

The Ricoh Aficio Color Digital Color Copier, Printer/Scanner Units are also similar to the merchandise which is the subject of NY Rulings 817475 and A80061.

In some instances Ricoh Corporation may import the Ricoh Aficio Color Series with the printer interface PCB, the interface harness and the pre-transfer lamp unit removed, packaged separately, and over-packed with the device.

The applicable subheading for the Ricoh Aficio Color 2000, 5000 series, and NC8115 of Digital Color Copier/Printer/Scanner units when imported in a fully assembled unit will be 8471.60.5200, Harmonized Tariff Schedule of the United States (HTS), which provides for other laser printer units, assembled, incorporating at least the media transport, control, and print mechanism. The rate of duty will be 1.5 percent ad valorem.

The applicable subheading for the Ricoh Aficio Color 2000, 5000 series, and NC8115 of Digital Color/Printer/Scanner units when imported with the printer interface PCB, the interface harness and the pre-transfer lamp removed, packaged separately, and over-packed with the device will be 8471.60.6200, HTS, which provides for other laser printer units. 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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