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NY F80927




December 27, 1999

CLA-2-84:RR:NC:1:110 F80927

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.60.5200

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

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

Dear Mr. Valdes:

In your letter dated December 5, 1999, you requested a tariff classification ruling.

The merchandise under consideration involves a multifunctional printer/copier unit, and a multifunctional printer/copier/fax unit that are known as the "Ricoh 150, and Ricoh 180. These machines are multifunctional digital imaging devices that perform printing, copying, and facsimile functions, and can be connected to an automatic data processing (ADP) system via optional printer controllers.

The Ricoh 150 unit is a multifunctional digital imaging system that performs printing and copying functions, specifically designed to be used as an output unit for laser printing. With optional printer controllers, this model in this Aficio series is capable of operating in a Local Area Network or client/server workgroup environment with printer server.

The Ricoh 150 unit produces digital black and white output at 600 x 600 dots per inch (dpi), with up to 256 graduations per dot. The unit weights 120 pounds and use laser print engines (electrophotographic process). The Aficio 150 prints up to 15 pages per minute. This model utilizes PCL 5e, PCL 6 and Adobe PostScript 3 and can be upgraded to include up to 80 MB of internal printer memory.

The Ricoh Aficio 180 unit is a multifunctional digital imaging system that performs printing, copying and facsimile functions specifically designed to be used to be used as an output unit for laser printing. With optional printer controllers, this model in this Aficio series is capable of operating in a Local Area Network or client/server workgroup environment with printer server.

The Ricoh Aficio 180 units produce digital black and white output at 600 x 600 dots per inch (dpi), with up to 256 graduations per dot. The unit weights 120 pounds and user laser print engines (electrophotographic process). The Aficio 180 prints up to 18 pages per minute. This model utilizes PCL 5e, PCL 6 and Adobe PostScript 3 and can be upgraded to include up to 80 MB of internal memory.

Both units employ automatic paper feeders with a total paper capacity of 1,350 sheets for the Aficio 180 and 350 sheets for the Aficio 150. These units are capable of printing on various paper sizes with a maximum output size of 11 inches by 17 inches.

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) 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 other multifunctional printer units that were the subject of NY Ruling Letters E80322, NY 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 150 and 180 multifunctional digital printer units 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 212-637-7019.

Sincerely,

Robert B. Swierupski
Director,

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