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May 12, 1999

CLA-2-84:RR:NC:1:110 E81729

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 30, 1999, you requested a tariff classification ruling.

The merchandise under consideration involves two models of multifunctional printer/copier/fax units that are known as the "Ricoh Aficios" 355 and 455. 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 Aficios" 355 and 455 are similar to the "Ricoh Aficios 340, 350, 450, 550, and 650 which were the subject of NY Ruling E80322. These machines are multifunctional products that offer copier, facsimile, and printer functions, which can operate independently and simultaneously with other functions operating in the background. The multifunction output is interleaved with the copy mode output.

The Ricoh Aficio 355 and 455 are similar to the Aficio 200, 250, and 401, except for some minor updates. These prior Aficio models were the subjects of NY Ruling D82304. All the machines are multifunctional imaging apparatus that perform printing, copying, scanning and facsimile functions, and are specifically designed to be used as output units for laser printing. With optional printer 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 subsidiary, Savin Corporation, but with different model designations than Ricoh's as follows:

Savin: 2035DP for Ricoh Aficio 355 and 2045DP for Ricoh Aficio 455.

The Aficios produce digital black and white output at 600 x 600 dots per inch (dpi), with 65 graduations per dot. The Aficios 355 and 455 print at 35 pages per minute. Each uses 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 a capability of printing on various paper sizes, with maximum output size of 11" x 17".

The Aficios 355 and 455 are capable of performing printing, copying, and facsimile functions, and are in one common housing. These machines 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) of 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 other multifunctional printer/copier/fax machines, which were the subject of NY Ruling Letters E80322 and NY D82304. 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 Aficios" 355 and 455 as well as the "Savin" comparable models, namely 2035DP and 2045DP 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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