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January 22, 1999

CLA-2-84:RR:NC:1:110 D86841

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.60.5200

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

RE: The tariff classification of a multifunctional printer/ copier/fax/telephone/answering machine from Japan.

Dear Mr. Shaw:

In your letter dated January 19, 1999 you requested a tariff classification ruling.

The merchandise under consideration involves a multi- functional printer/fax/copier/telephone/answering machine which is known as the model KX-PLM650. This multifunctional printer can be connected to a central processing unit (CPU) which enables this unit to function within the framework of a local area network (LAN) environment.

The Panasonic KX-PLM650 has a printing capacity of 8 pages per minute with a printing resolution of 600 by 600 dots per inch. This entire multifunctional printer is built off of the Printer Engine. All of the functions of the machine (printer, copier, fax, and scanner) except the telephone and answering machine utilize the Printer mechanism to operate. This multi- functional printer can be connected to an ADP system via its parallel I/F (IEEE1284) port. The cost of the printer engine comprises 75 percent of the value of the machine.

The model KX-PLM650 is capable of performing printing, faxing, copying, scanning, telephonic, and answering machine functions within one common housing. It therefore meets 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, this composite good would be classified as if it consists of the material or component which gives this machine its “essential character”. Noting its high print speed and the fact that this unit is most efficient as a networked printer, it would appear to have an “essential character” of a networked automatic data processing machine document printer.

This model is also similar to other multifunctional printers which were the subject of NY Ruling Letters D85615 and D83998. The model KX-PLM650 also meets the definition of a “unit” of an automatic data processing system as per Legal Note 5(B) of Chapter 84 to the HTS.

The applicable subheading for the Panasonic model KX-PLM650 multifunctional printer will be 8471.60.5200, Harmonized Tariff Schedule of the United States (HTS), which provides for other laser printer units. 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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