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April 9, 1999

CLA-2-84:RR:NC:1:110 E80322

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.60.5100

Mr. Raymond A. Valdes
Ricoh Corporation
Five Dedrick Place
West Caldwell, N.J. 07006

RE: The tariff classification of multifunctional printer/copier/fax units from Japan.

Dear Mr. Valdes:

In your letter dated April 2, 1999, you requested a tariff classification ruling.

The merchandise under consideration involves five models of multifunctional printer/copier/fax units, which are known as the "Ricoh Aficio" 340, 350, 450, 550 and 650 (Aficios). These machines are multifunctional imaging devices, which perform printing, copying, scanning, and facsimile functions, and can be connected to an automatic data processing (ADP) system via optional printer controllers .

The "Ricoh Aficio" 340, 350, 450, 550, and 650 are similar to the "Ricoh Aficio" 200, 250 and 401, which was the subject NY Ruling D82304. All the machines are multifunctional imaging apparatus that perform printing, copying, scanning and facsimile functions, and are designed to be used as output units for laser printing. With the optional print controllers, each model in the "Aficio" series is capable of operating in a Local Area Network or client/server workgroup environment with printer server.

Ricoh Corporation also imports these models for use by their Savin and Gestetner Corporation subsidiaries under different model designations as follows:

Savin: 9935D for Aficio 340; 9935DP for Aficio 350; 9945DP for Aficio 450; 9955DP for Aficio 550 and 9965DP for Aficio 650

Gestetner: 3235s for Aficio 340; 3235 for Aficio 350; 3245 for Aficio 450; 3255 for Aficio 550 and 3265 for Aficio 650

The Aficios produce digital black and white output at 600 x 600 dots per inch (dpi), with 65 graduations per dot. The Aficios 340/350 each print 35 ppm; the 450, 45 ppm; the 550, 55 ppm; and the 650, 65 ppm. Each employs laser print engines (electrographic process), and utilize PCL 6 with Post Script 3 (option upgrade), and can be upgraded to include up to 72 MB of internal printer memory. The Aficios all have automatic paper feeders, and paper capacity from 3, 100 to 3, 500 sheets, with capability of printing on various paper sizes with maximum output size of 11" x 17".

These machines are capable of performing printing, copying, and facsimile functions, and are in one common housing. They all meet 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, these composite goods would thus be classified as if they consisted of the material or component, which gives them their "essential character". Noting their high print speed and the fact that these units are the most efficient as networked printers, they would appear to have an "essential character" of a networked automatic data processing machine document printer.

These models are also similar to the other multifunctional printer/copier/fax machines, which were the subject of NY Ruling Letters D82304 and NY C83939. These models also meet the definition of a "unit" of an ADP system, as per Legal Note 5(B) to Chapter 84 of the HTS.

The applicable subheading for the "Ricoh Aficio" 340, 350, 450, 550 and 650 as well as the "Savin" comparable models, namely 9935D. 9935DP, 9945DP, 9955DP and 9965DP and "Gestetner" comparable units, namely 3235s, 3235, 3245, 3255 and 3265 will be 8471.60.5100, Harmonized Tariff Schedule of the United States (HTS), which provides for 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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