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NY B85802




May 21, 1997

CLA-2-84:RR:NC:1:110 B85802

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.60.6200

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

RE: The tariff classification of a multifunction printer from Japan.

Dear Mr. Peterson:

In your letter dated May 13, 1997, on behalf of Xerox Corporation, you requested a tariff classification ruling.

The merchandise under consideration involves a Xerox "Document WorkCentre Pro 745 multifunctional printer" which is a multifunctional device designed to be used as a low-speed printer for automatic data processing "(ADP)" systems. In addition to the printing function, this device incorporates features which allow it to operate as a facsimile transceiver, digital scanner, and as a low-speed digital photocopier.

The principal use of the D-745 will be as an output printer for computer systems. This device features a ten page per minute electrostatic laser printer engine, which is capable of making laser copies on plain paper with a 400 x 400 dots per inch (dpi) resolution, as well as with a simulated 600 x 600 dpi resolution in compressed format. The D-745 features a 38 pin bi-directional parallel port interface that is compatible with "Windows 3.1" or "Windows 95", which allows it to be utilized as the output printer for an ADP system.

In addition to functioning as an ADP output printer, the D-745 features a digital scanner which has an ADF scan capacity of up to 50 pages, with a resolution of 400 x 400 dots per inch. Scanning functions for the unit are performed by the light emitting diode (LED) scanner array located near the cover of the printer. This device can be used to scan "hard copy" documents into memory, for later retrieval and for limited manipulation.

Another additional function of the D-745 is as a facsimile transceiver. In fax mode, this device features dual telephone fax ports, a class 2.0 modem, ITU-U standard subaddressing capabilities, and a modem transmission rate of 14,400 MMR bits per second. The facsimile functions are located on a printed wiring board assembly located in the interior of the printer, and depend upon the connection of the device by modem to a telephone network. Other features of the D-745 include dual modems and local area network (LAN) connectivity which permits the printer to interface with network scanning and faxing programs.

Finally, the D-745 can be utilized as a "convenience" copier, with a capability to scan documents into memory, and print copies at a rate of up to 10 pages per minute. The remaining components of the printer are devoted to printer functions by the creation of images on paper through an electrostatic process by the processing of digital data streams.

The components of the D-745 which are dedicated to the printing function include the printer engine, the printer control, the main printed wiring board assembly, the paper handling systems, the power supply, the memory wiring board assemblies, operator interfaces and covers. Xerox intends to import the D-745 with the printer toner cartridge removed, packaged separately, and over packed with the device. This cartridge which contains the print mechanism for the device, will be installed by the customer after importation. It is thus not an "assembled" printer.

The D-745 multifunction printer 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 facsimile transceiver, digital scanner, telephone transceiver, and local photocopier, its principal use appears to be as an output printer for ADP machines. Noting Legal Note 7 of Section XVI of the HTS, "a machine which is used for more than one purpose is, for the purpose of classification, to be treated as if its principal function were its sole purpose". The D-745 multifunction printer is also similar to the multifunction printing devices which were the subject of HQ's Letter 958124 and NY Letter A87808.

The applicable subheading for the "Document WorkCentre Pro 745 multifunctional printer" will be 8471.60.6200, Harmonized Tariff Schedule of the United States (HTS), which provides for 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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