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April 19, 1999

CLA-2-84:RR:NC:1:110 E80642

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.60.5100

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

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

Dear Mr. Valdes:

In your letter dated April 7, 1999, you requested a tariff classification ruling.

The merchandise under consideration involves the Ricoh Aficio Color 3006, 4106, 6010 and 6110 Digital Color Copier/Printer/Scanner units. These machines are designed to be used as output units in an automatic data processing (ADP) system environment, in addition to functioning as a copier.

Ricoh Corporation imports these machines for their subsidiaries, Savin Corporation and Gestetner under different model designations, as follows:

Aficio 3006 is Savin SDC 306; Aficio 4106 is Savin SDC 306E; Aficio 6010 is Savin SDC 410, and Aficio 6110 is Savin SDC 410E.

Aficio 3006 is Gestetner CS206; Aficio 4106 is Gestetner 206de; Aficio 6010 is Gestetner CS210; and Aficio 6110 is Gestetner CS 210e.

The Ricoh Aficio 3006, 4106, 6010 and 6110 Digital Color Copier/Printer/Scanner units are multifunctional print servers, which in their configuration connected to a Fiery Color server allow these devices to function as printers on a network supporting multiple computer platforms. These platforms include personal computers, Mac, and Unix workstations such as Silicon Graphics and Sun Sparc workstations.

The engines for these machines are Raster Output devices, which are capable of scanning hardcopy originals to create a master or "Digital Original". These digital originals can then reproduce through its electrophotographic process via the laser print engine to produce full color or black and white prints.

These Ricoh Aficio Color 3006, 4106, 6010 and 6110 units are all multifunctional devices that consist of a single unit, which incorporates electrostatic photocopying and laser ADP output function. The laser printing and photocopying functions share a single electrostatic imaging system, which produces images by adhering color toners to plain paper by means of a photoconductor drum.

The Ricoh Aficio Color units also feature digital scanning, which is used in connection with document production and document creation. The scanner serves as an input device allowing document images to be scanned electronically. These digital files are shared among graphics users that are networked in color workgroups. In addition, the same digital file can be sent electronically through most networks allowing multiple users to print their files both color and black and white from any designated Aficio color printer engine.

The Aficio Color 3006 and 4106 print up to 21/28 pages per minute in black or four prints per minute in color. The Aficio 6000 series prints up to 40 prints per minute in black and white or up to 10 prints per minute in color.

The Ricoh Aficio Color Series 3006, 4106, 6010, 6110 all meet the definition of a "composite good" made up of different components, which are described, in different provisions of the HTS. Although these models may be used as digital copiers, they appear to be principally used as digital printers for ADP network systems. Noting GRI-3(b), the "essential character" of these digital copier/printer/scanners appears to be as networked printers. The units also meet the definition of a "unit" of an automatic data processing system as per Legal Note 5(B) of Chapter 84 to the HTS. These machines are also similar to the "Ricoh Aficio Color 2000 and 5000 series, which were the subject of NY Ruling Letter B84344.

The applicable subheading for the Ricoh Aficio Color 3006, 4106, 6010 and 6110 Digital Color Copier/Printer/Scanner units 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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