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NY C86219




April 8, 1998

CLA-2-84:RR:NC:1:110 C86219

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.60.6400

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 ink jet printers when shipped in the same carton as detached printing mechanisms from Japan.

Dear Mr. Grace:

In your letter dated April 2, 1998, on behalf of Canon Latin America, Inc., you requested a tariff classification ruling.

The merchandise under consideration involves five different models of Canon Color bubble Jet Printers when the individual printers are imported in the same shipping cartons as BJ ink cartridges which serve as their printing mechanism. The models in question are the BJC-240, BJC-250, BJC-620, BJC-4200, and the BJC-4550 Color Bubble Jet Printers.

Canon Latin America plans to import these printers and ink cartridges, which contain the print head units, in the same shipping cartons. Although these bubble jet ink cartridges will be imported in the same cartons as the printers, they will be detached from the printer assemblies and enclosed in separate sealed containers. These bubble jet ink cartridges will thus be "overpacked" with the printer assemblies, and will not be installed in the printers until after the units have been purchased by retail customers.

Noting that the Canon BJC-240, BJC-250, BJC-620, BJC-4200, and the BJC-4550 Series of Color Bubble Jet printers and the Color BJ cartridges are packed separately from the ink jet printers, the printers should be treated as "unassembled units" even though the shipping cartons in questions will contain five partially assembled ink jet printers, and five Color BJ cartridges in the same carton as detached printing mechanisms. Bubble jet printers shipped in the same carton as detached printing mechanisms, and thus not fully assembled units were recently the subject of NY Ruling Letters C84386 and NY C80114. The applicable subheading for the Canon BJC-240, BJC-250, BJC-620, BJC-4200, and the BJC-4550 Color Bubble Jet Printers shipped as five partially assembled ink jet printers, and five sealed Color BJ cartridges separately packed, and imported in the same shipping carton will be 8471.60.6400, Harmonized Tariff Schedule of the United States (HTS), which provides for other ink jet 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
Director,

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