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NY D80821


August 7, 1998

CLA-2-84:RR:NC:1:110 D80821

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.60.5100

Mr. James Shaw

Panasonic Logistics Company of America

2 Panasonic Way

Secaucus, N.J. 07094

RE: The tariff classification of multifunctional digital copier/printers from Japan

Dear Mr. Shaw:

In your letter dated July 31, 1998, you requested a tariff classification ruling.

The merchandise under consideration involves the models

FD-D350 and FP-D350H digital copier/printers. These machines feature high resolution 600 X 600 copying and printing (600 DPI). The copy process is a Laser Electrostatic photographic method. The machines can print 35 copies per minute. The FD-D350 and the

FP-D350H have the capacity to print on various paper sizes which range from 4 x 6 inches through 11 x 17 inches. The machines can reduce images to 50% or increase the size to 200% of the original. The units can be networked so that any personal computer (PC) in the company can be connected via a Local Area Network (LAN).

The FD-D350 and FP-D350H multifunctional digital copier/ printers can operate either as a copier or receive and print documents from a (PC). The units have a standard 8 megabyte memory that is expandable to 512 megabytes. It can translate information from Windows, NetWare or Unix Operating Systems. These multifunctional digital copier/printers also operate as a scanner. They employ a "Scan Once", "Print Many" feature which saves wear and tear on the copier. The user can have instant access to any document since these models can copy, scan, print, store, file and retrieve data. The filing and retrieval is achieved through a Network Connection, a 2 GB Hard Disk, or an internal Zip Drive.

The FD-D350 and FP-D350H meet the definition of a "composite good" (printer, copier, scanner) made up of different components which are described in different provisions of the HTS. Although these two models of digital copier/printers may be used as digital copiers, they appear to be principally used as digital printers for automatic data processing (ADP) network systems. The digital copying function is a subsidiary function which also utilizes the product's laser printing components. Noting GRI-

3(b), the "essential character" of these digital copier/printers appears to be as network printers. These machines are also similar to the multifunctional copier/printer devices which are noted in NY Ruling Letters C85191 and C83939.

The applicable subheading for the model FD-D350 and FP-D350H multifunctional digital copier/printers will be 8471.60.5100, Harmonized Tariff Schedule of the United States (HTS), which provides for assembled laser printer units incorporating at least the media transport, control and print mechanisms; 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,


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