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NY D83998




October 30, 1998

CLA-2-84:RR:NC:1:110 D83998

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.60.5100; 8471.60.5200

Mr. Raymond A. Valdes
Ricoh Corporation
Five Dedrick Place
West Caldwell, N.J. 07006

RE: The tariff classification of multifunctional printer/copier/fax units from Japan.

Dear Mr. Valdes:

In your letter dated October 20, 1998, you requested a tariff classification ruling.

The merchandise under consideration involves three models of multifunctional printer/copier/fax units which are known as the Gestetner 3220, 3225, and 3240. These digital imaging machines can be connected to a printer controller which enables these units to function within the framework of a local area network or client server workgroup environment with printer server.

The Gestetner 3220 and 3225 produce digital black and white output at 600 by 600 dots per inch (dpi), with up to 64 graduations per dot. They weigh 127 pounds each and use laser print engines that utilize an electrophotographic process. The Gestetner 3220 prints up to 20 pages and the 3225 prints up to 25 pages per minute. Both models utilize PCL 5e and can be upgraded to include up to 34 MB of internal printer memory.

The Gestetner 3240 produces digital and white output at 600/400/300 dots per inch (dpi), with up to 256 graduations per dot. It prints up to 40 pages per minute with 8 « inch by 11 inch paper at 300 or 400 dpi, or 20 pages per minute with 8 « inch by 11 inch paper at 600 dpi. The three models have automatic paper feeders, and have a total paper capacity of 3,100 sheets for the Gestetner 3220, 2850 sheets for the Gestetner 3225, and finally 3500 sheets for the Gestetner 3240. These units are capable of printing on various paper sizes, and have a maximum paper capacity of 11 inches by 17 inches.

These machines are capable of performing printing, copying, and facsimile functions, and are in one common housing. They all meet the definition of a composite good made up of different components which are described under different provisions of the HTS. Noting GRI-3(b) to the HTS, these composite goods would thus be classified as if they consisted of the material or component which gives them their "essential character". Noting their high print speed and the fact that these units are the most efficient as networked printers, they would appear to have an "essential character" of a networked automatic data processing machine document printer.

These models are also similar to other multifunctional printer/copier/fax machines which were the subject of NY Rulings D82304 and NY C83939. These models also meet the definition of a "unit" of an ADP system, as per Legal Note 5(B) to Chapter 84 of the HTS.

The applicable subheading for the Gestetner 3225 and 3240 units will be 8471.60.5100, Harmonized Tariff Schedule of the United States (HTS), which provides for laser printers units, capable of producing more than 20 pages per minute. The rate of duty will be free.

The applicable subheading for the Gestetner 3220 multi- functional printer will be 8471.60.5200, HTS, which provides for other laser printer unit. The rate of duty will be 0.5 percent ad valorem.

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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