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NY F84041




March 31, 2000

CLA-2-84:RR:NC:1:110 F84041

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.60.6400

Mr. David R. Grace
Covington & Burling
1201 Pennsylvania Avenue, N.W.
P.O. Box 7566
Washington, D.C. 20044-7566

RE: The Tariff Classification of Canon LR1 PrintStation Color Bubble Jet Printers from Japan.

Dear Mr. Grace:

In your letter dated March 3, 2000, on behalf of Canon Computer Systems, Inc. (CCSI), you requested a tariff classification ruling.

The merchandise under consideration involve the Canon LR1 PrintStation Color Bubble Jet (BJ) Printer when it is imported in the same carton as the Color BJ ink cartridges which serve as its printing mechanism. The printer was designed for use with Web TV internet appliances but can also be used as a computer output unit. The specifications of the printer is given at 720 by 360 dpi printing resolution with a printing speed of 4 ppm for black and white, 2 ppm for color, having both an IEEE 1284 and USB interface.

The Canon LR1 PrintStation is capable of printing in black and white and color. Three different cartridges may be installed; the BC-11e Color BJ Cartridge, the BC-10 Black BJ Cartridge and the BC-12e Photo Color BJ Cartridge. Only one cartridge is installed at a time, and thus the user needs to change cartridges depending on his printing needs.

The BC-10 Black BJ Cartridge incorporates a Bubble Jet print head and a black ink reservoir. The print head contains 128 nozzles.

The BC-11e Color BJ Cartridge incorporates a Bubble Jet print head and four ink reservoirs containing black, cyan, magenta, and yellow ink. The print head for the BC-11e Color BJ cartridge contains a total of 136 nozzles; 64 nozzles for black and 24 nozzles for each of the three colors.

The BC-12e Photo Color BJ Cartridge incorporates a Bubble Jet print head and reservoirs containing black, cyan, magenta, and yellow ink. As in the case of the BC-11e, the photo cartridge print head contains a total of 136 nozzles; 64 nozzles for black and 24 nozzles for each of the three colors.

The BC-10, BC-11e and BC-12e cartridges are designed for use in Canon’s BJC printers and have no other uses. Each nozzle on the print head units contains a heater. When the heater is turned on, ink is vaporized forming an air bubble. As the bubble expands, ink is expelled out of the open end of the chamber. Upon striking the print media, the expelled ink forms a contrasting dot. The selective printing of dots results is the final image. Without a print head unit, no printing can be performed.

Although the printer and the ink cartridges (which contain the print head units), will be imported in the same shipping cartons, they will be detached from the printer assembly and enclosed in a sealed plastic container. Thus in its imported condition, the LR1 PrintStation does not represent an assembled printer.

According to Legal Note 5(D) to Chapter 84, HTS, if a printer is connectable to the central processing unit either directly or through one or more other units, and is able to accept or deliver data in a form (codes or signals) which can be used by the system, then it can be classified within heading 8471, HTS, as an ADP unit. While the Canon LR1 PrintStation printer is not of a kind solely or principally used in an automatic data processing system, it is equipped with both an IEEE 1284 and USB interface that can be connected to a personal computer. Based upon the application of Legal Note 5(D) to Chapter 84, HTS, we find that the subject printer is classifiable under heading 8471, as a printer.

The applicable subheading for the Canon LR1 PrintStation Color Bubble Jet Printer when the print head cartridges are not installed in the printer but rather are separately packed in the same shipping carton as detached printing mechanisms will be 8471.60.6400, Harmonized Tariff Schedule of the United States (HTS), which provides for other ink jet printers. 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 Eileen Kaplan at 212-637-7048.

Sincerely,

Robert B. Swierupski
Director,

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