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NY D85703




December 17, 1998

CLA-2-84:RR:NC:1:110 D85703

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.60.6500

Ms. Sandra Liss Friedman
Barnes, Richardson & Colburn
475 Park Avenue South
New York, N.Y. 10016

RE: The tariff classification of computer label printers from Japan.

Dear Ms. Friedman:

In your letter dated December 7, 1998, on behalf of Brother International Corp., you requested a tariff classification ruling.

The merchandise under consideration involves the model PT-2500PC and the model PT-9200PC P-TouchPC computer label printers which operate as output units for personal computers to create customized adhesive backed labels.

These P-Touch PC label printers are compatible with any personal computer that operates in a Microsoft Windows or Macintosh environment. After a customized label is designed on the personal computer, the P-TouchPC prints out the label using a thermal transfer printhead. The PT-9200PC is a more upscale version of the PT-2500PC. It is capable of printing at a higher resolution and in more print fonts and sizes. The PT-9200PC will be marketed for the commercial user whereas the PT-2500PC market will be for the home office user. The units are connected to a personal computer through a serial interface cable.

The P-Touch PC label printer tape cassettes contain three spools of different printing media materials. One of the spools contains the adhesive plastic tape onto which the letters or designs are printed. This tape actually acts as the finished label after it is printed and peeled from its paper backing. A second spool contains the colored plastic tape which is the "inked" material which prints onto the plastic label. The inked ribbon is then rewound inside the cartridge. The third spool contains a clear plastic strip which covers the colored tape which is printed onto the adhesive label. These printers are imported without the assembly of a tape cassette, and are thus considered to be unassembled printers. The tape cassette is always packaged separately, but shipped in the same shipping carton.

The P-TouchPC computer label printers are similar to other label printers that are used in conjunction with computer output units. Labeling machines which operate via a commuter interface were the subject of NY Ruling Letters 898221 and 875724. These P-TouchPC computer label printers also meet the definition of automatic data processing machine units as per Legal Note 5(B) and 5(D) of Chapter 84 to the HTS.

The applicable subheading for the model PT-2500PC and the model PT-9200PC P-TouchPC computer label printers will be 8471.60.6500, Harmonized Tariff Schedule of the United States (HTS), which provides for other thermal transfer 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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