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NY C87602




May 8, 1998

CLA-2-84:RR:NC:1:110 C87602

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 the Canon BJC-5000/BJC-500J Color Bubble Jet Printers from Mexico.

Dear Mr. Grace:

In your letter dated May 4, 1998, on behalf of Canon Business Machines, Inc., you requested a tariff classification ruling.

The merchandise under consideration involves the Canon BJC-5000 Color Bubble Jet Printers when individual units are imported in the same shipping cartons as BJ ink cartridges which serve as their printing mechanism. This printer model is also known as the Canon BJC-500J Color Bubble Jet Printer. The BJC-5000/BJC-500J Color Bubble Jet Printer is designed for use as a computer output device.

The BJC-5000/BJC-500J Color Bubble Jet Printers are capable of printing in black and white or color. However, before they can function as printers, cartridges containing ink jet print heads must be installed. The BJC-5000/BJC-500J is a "dual head" machine with two separate cartridge slots. Any of three different print head cartridges may be installed in either slot. These print head cartridges are known as the BC-23 Enhanced Black BJ Cartridge; the BC-21e Color BJ Cartridge, and/or the BC-22e Photo BJ Cartridge.

The BJC-5000/BJC-500J optimizes the printing process based upon the combination of cartridges installed in the machine. The BC-23 Enhanced Black BJ Cartridge incorporates a bubble jet print head and a black ink reservoir. Each print head contains 128 nozzles. When the ink runs out, the entire cartridge is replaced.

The BC-21e Color BJ Cartridge incorporates a bubble jet print head and two replaceable ink tanks (the BCI-21 Black Ink Cartridge and the BCI-21 Tri-Color Ink Cartridge). The print head for the BC-21e Color BJ cartridge contains 64 nozzles for black ink and 72 nozzles for color (24 nozzles for each color).

The BC-22e Photo BJ Cartridge incorporates a bubble jet print head and an ink reservoir. The print head contains 64 nozzles for black ink and 72 nozzles for color (24 nozzles for each color). When the ink runs out, the entire cartridge is replaced.

All of the cartridges utilize the same technology. Each nozzle on the print head units contains a heater. When the heater is turned on, ink is vaporized forming an air bubble. As the bubble expands, ink is expelled out of the open end of the chamber. Upon striking the print media, the expelled ink forms a contrasting dot. The selective printing of dots results in the final image. Without a print head unit, no printing can be performed.

Noting Legal Note 5(B) to Chapter 84 of the HTS, the BJC-5000/BJC-500J Color Bubble Jet printers would meet the definition of a "unit" of an ADP system. Although the printer and the ink cartridges (which contain the print head units), will be imported in the same shipping cartons as the BJC-5000/BJC-500J printers, they will be detached from the printer assembly and enclosed in sealed containers. The BJ ink cartridges will thus not be installed in the printers at the time of importation. Rather, they will only be installed in the printers when they have been purchased by retail customers in the United States. Bubble Jet Printers shipped in the same carton as detached printing mechanisms, and therefore not fully assembled units were the subject of NY Ruling Letters C86924 and NY C86219.

The applicable subheading for the Canon BJC-5000/BJC-500J Color Bubble Jet Printers when the print head cartridges are not installed in the printer but rather are separately packed in the same shipping carton as detached printing mechanisms 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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