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NY C84928




March 3, 1998

CLA-2-84:RR:NC:1:110 C84928

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.60.6100

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 February 24, 1998, on behalf of Canon U.S.A., Inc., you requested a tariff classification ruling.

The merchandise under consideration involves two multi- functional copiers-printers which are known as the "Kodak ColorEdge" 1560 and 1565 Copier-Printers. Both models are designed to be used as output units for automatic data processing (ADP) machines. Each unit incorporates a "Standard Centronic" compatible parallel interface port. Using these ports, the units may be connected to ADP machines by adding a color controller. This enables the Kodak ColorEdge 1560 and 1565 Copier-Printers to operate within an ADP machines environment.

The Kodak ColorEdge 1560 and 1565 Copier-Printers provide digital color image quality. They produce digital color output at 400 by 400 dots per inch (dpi), with up to 256 graduations per color. Both machines are also capable of printing in black and white. The Kodak ColorEdge 1560 and 1565 Copier-Printers employ a dry laser electrophotostatic development process. Both models are capable of printing at the rate of 7 full color pages per minute (ppm) or 28 black and white ppm. They have an automatic paper feeder. A toner cartridge must be installed before the machine can function as a printer.

Although the Kodak ColorEdge 1560 and 1565 Copier-Printers may be used as "stand alone" digital copiers, they were specifically designed to serve as fast network printers for corporations, graphic professionals, and so-called "print for pay" operations. These two copier-printers are utilized to create high quality graphics, using such application software as Powerpoint, Quark, Photoshop, Pagemaker, and Corel Draw. Therefore, the ColorEdge 1560 and 1565 were designed to provide the high level of printer performance required for these latter types of applications. The digital copying function is a subsidiary function which also utilizes the product's laser printing components.

The Kodak ColorEdge 1560 and 1565 Copier-Printers 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 appear to be as networked output printers for ADP systems. These two models of color laser copier-printers are also similar to the multifunction copier-printer devices noted in NY Ruling Letters C83939 and C81666.

Canon U.S.A. intends to import the Kodak ColorEdge 1560 and 1565 Color Laser Copier-Printers without the toner cartridges. In their condition as imported, these Canon Kodak ColorEdge multifunctional units are not "assembled" printers as per Heading 8471.60.51 and Heading 8471.60.52.

The applicable subheading for the Kodak ColorEdge 1560 and 1565 multifunctional Color Laser Copier-Printers will be 8471.60.6100, Harmonized Tariff Schedule of the United States (HTS), which provides for other laser printers 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,

Robert B. Swierupski
Director,

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