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NY C81666




November 19, 1997

CLA-2-84:RR:NC:1:110 C81666

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 multifunctional Color Laser Copiers/Printers from Japan.

Dear Mr. Grace:

In your letter dated November 11, 1997, you requested a tariff classification ruling.

The merchandise under consideration involves four multifunctional copiers/printers in the CLC series, which are known as the CLC 320, the CLC 700L, the CLC 700S, and the CLC 800S. Each CLC unit incorporates a "Standard Centronic" compatible parallel interface port. Using these ports, the CLC copiers/printers may be connected to ADP machines by the use of ColorPASS controllers. All four models in the CLC series are fully capable of operating in a networked computer environment.

The CLC 320 provides digital color image quality. It produces digital color output at 400 X 400 dots per inch (dpi), with 256 graduations of color. It is also capable of printing in black and white. The CLC 320 employs a dry laser electro- photostatic development process. The CLC 320 is capable of printing at the rate of 5 color pages per minute (ppm), or 20 black and white ppm. It has an automatic paper feeder and a total paper capacity of 500 sheets. When coupled to a Canon ColorPASS controller, the CLC 320 becomes a high quality color ADP printer.

The CLC 700S produces digital color output at 400 x 400 dpi, with up to 256 graduations per color, and is also capable of printing in black and white. The CLC 700S employs a dry laser electrophotostatic development process. The CLC 700S is capable of printing at the rate of 7 full color ppm or 28 black and white ppm. It has an automatic paper feeder and a total paper capacity of 1,050 sheets. The CLC 700S is capable of connecting to the Canon ColorPASS Controller for ADP color printing.

The CLC 700L shares numerous characteristics with the CLC 700S. It is capable of printing at the rate of 7 full color ppm or 28 black and white ppm. This device has an automatic paper feeder and a total paper capacity of 2,050 sheets. It is capable of printing on various paper sizes, with a maximum output size of 11 inches by 17 inches. The CLC 700L is also designed to be connected to the Canon ColorPASS Controller, for high resolution ADP color printing.

The CLC 800S shares numerous characteristics with the CLC 800. It provides digital color image quality at 400 by 400 dpi, with up to 256 gradations per color, and is also capable of printing in black and white. It also employs a dry laser electrophotostatic development process. The CLC 800S is capable of printing at the rate of 7 full color ppm or 28 black and white ppm. It has an automatic paper feeder and a total paper capacity of 1,550 sheets. It is capable of printing on various paper sizes, with a maximum output size of 11 inches by 17 inches. The CLC 800S has the capacity to generate photos, technical drawings and color proofs from any application or ADP computer workstation.

Although these four models of CLC multifunctional color laser copier/printers may be used as digital copiers, they appear to be specifically designed for principal use as color printers for ADP network systems. The digital copying function is a subsidiary function which also utilizes the product's laser printing components.

The CLC 320, the CLC 700L, the CLC 700S, and the CLC 800S meet the definition of a "composite good" made up of different components which are described in different provisions of the HTS. The principal use of these multifunctional color laser copier/printers appears to be as networked output printers for ADP systems. The four models of color laser copier/printers are also similar to the multifunction copier/printer devices noted in NY Ruling Letters B88291, and B84344.

Canon U.S.A. intends to import the CLC 320, the CLC 700L, the CLC 700S, and the CLC 800S Color Laser Copier/Printers without the toner cartridges. In their condition as imported, these Canon CLC series multifunctional units are not "assembled" printers as per Heading 8471.60.51 and Heading 8471.60.52.

The applicable subheading for the model CLC 700L, the CLC 700S, and the CLC 800S multifunctional Color Laser Copier/ Printers 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.

The applicable subheading for the model CLC 320 multi- functional Color Laser Copier/Printer 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
Director,

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