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NY D85371




December 11, 1998

CLA-2-84:RR:NC:1:110 D85371

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.60.1095; 8473.30.1000; 8524.99.6000

Mr. James Shaw
Panasonic Logistics Company of America
2 Panasonic Way
Secaucus, NJ 07094

RE: The tariff classification of Panaboards and interface units from Japan

Dear Mr. Shaw:

In your letter dated December 7, 1998, you requested a tariff classification ruling.

The merchandise under consideration involves three models of Panaboards (KX-B530, KX-B630, and KX-B730) and two models of Interface units (KX-B091 PC interface, and KX-B09 printer interface) that are used with the Panaboard units.

The three models of Panaboards are basically electronic whiteboards that are designed for writing information unto the board at lectures and conferences, and then have the ability to copy and print out the information, and even store, fax and network the information by computer. The KX-B530 and KX-B730 are both approximately 3 feet by 4 1/2 feet in size, while the model KX-B630 is 3 feet by 6 feet in size. Although these Panaboards can function as an independent print board without the use of a computer, they are designed and marketed to function primarily as a computer input/output printer unit. All three of the models use a CCD image sensor, thermal print head as its copying system.

The three models of Panaboards are performing not only a copy/print function, but appear to be principally designed and used as a display, storing, fax, or networking device with a computer. It is thus a composite good, whose principal function would appear to be for computer input/output functions.

In order to utilize the Printer or PC interface, the user must use the optional interface cards. The cards are attached to a connector on the internal scanner located in an opening under the Panaboard. Proprietary software must also be installed to operate the computer functions. The KX-B09 printer interface kit, that allows the user to transfer the data directly to a laser printer, which consists of one proprietary interface board, interface cable, manual and registration card, when separately shipped, would meet the definition of a "set" as per GRI-3 (b). The essential character of this set would be exemplified by the proprietary interface board.

The model KX-B091 PC interface kit consists of one proprietary interface board, one interface cable, one 3.5 1.44 MB floppy disk, and manual. This kit allows the Panaboard to scan the images on the screen of the Panaboard in the Microsoft Windows operating system environment, display the images, and print the images which have been saved. The essential character of this set would also be the proprietary interface board.

The applicable subheading for the three models of Panaboard units will be 8471.60.1095, Harmonized Tariff Schedule of the United States (HTS), which provides for combined input/output units. The rate of duty will be free.

The applicable subheading for the two interface kits, when separately shipped, will be 8473.30.1000, HTS, which provides for parts and accessories of the machines of heading 8471; printed circuit assemblies. The rate of duty will be free. The proprietary software disks, noting Legal Note 6 to Chapter 85 of the HTS, would be separately classified under HTS number 8524.99.6000. The rate of duty will be 1.3 cents per square meter of recording surface. Effective January 1, 1999, the rate will be free of duty.

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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