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February 25, 1999

CLA-2-84:RR:NC:1:110 D87961

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.60.6100

Mr. Fusae Nara
Winthrop, Stimson, Putnam & Roberts
One Battery Park Plaza
New York, N.Y. 10004-1490

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

Dear Mr. Nara:

In your letter dated February 12, 1999, on behalf of Sharp Electronics Corporation, you requested a tariff classification ruling.

The merchandise under consideration involves the models AR-5132 and AR-335 digital copier/printers which incorporate a laser printer engine. Both models are designed to be used as output units in an automatic data processing (ADP) machine environment, in addition to functioning as a copier.

When an optional controller board is attached, the AR-5132 and the AR-335 function as a printer. Documents can be printed from a personal computer directly connected to the parallel port of either model or from personal computers connected to model AR-5132 or model AR-335 by means of a local area network (LAN).

The AR-5132 features 400 dots per inch (dpi) resolution and is capable of printing more than 20 pages per minute when printing on standard letter size paper. The resolution of the AR-335 is 600 dpi. It is also capable of printing more than 20 pages of standard letter size paper per minute.

The AR-5132 and AR-335 multifunctional digital copier/ printers also function as digital copiers. When used as copiers, the merchandise produces black and white copies with 256 levels of gradation. The digital copier incorporates a scanning mechanism that reads the document to be copied, which is converted into digital signals, which are then fed to the internal printer memory. A copy of the document is then printed from the internal printer memory by using the laser print mechanism. Thus when the subject multifunction equipment is used as a digital copier, the system uses the same laser printer engine that is used for printing documents when the product is used as a printer. The AR-5132 and AR-335 meet the definition of a “composite good” (printer, copier) 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 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/printers devices which are noted in NY Ruling Letters D85157, NY D80821, and NY D80267.

The applicable subheading for the model AR-5132 and AR-335 multifunctional digital copier/printers will be 8471.60.6100, Harmonized Tariff Schedule of the United States (HTS), which provides for other laser printer units 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 212-637-7019.

Sincerely,

Robert B. Swierupski
Director,

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