MESSAGE NO: 1267115 DATE: 09 24 1991
CATEGORY: ADA TYPE: ORD
REFERENCE: REFERENCE DATE:
CASES: A - 588 - 818 - -
- - - -
- - - -

PERIOD COVERED: 08 28 1991 TO

LIQ SUSPENSION DATE:

TO: REGIONAL DIRECTORS, COMMERCIAL OPERATIONS
DISTRICT DIRECTORS, AREA AND PORT DIRECTORS

FROM: DIRECTOR, IMPORT SPECIALIST DIVISION

RE: ANTIDUMPING DUTY ORDER ON PERSONAL WORD PROCESSORS FROM
JAPAN


1267115
September 24, 1991

interested parties.
1.On August 28, 1991 the Department of Commerce published an
antidumping duty order on personal word processors from Japan.

2.The marchandise covered by this investigation consists of
integrated personal word processing systems and major finished
units thereof ("word processors"), which are defined as devices
designed principally for the composition and correction of text.
All word processors within the scope of this investigation have
the following essential features: (1) a customized operating
system designed exclusively for a manufacturer's word processor
product line which is unable to run commercially available
software and which is permanently installed by the manufacturer
before or after importation; (2) a word processing software/
firmware program which is designed exclusively for the word
processor product line and which is permanently installed by the
manufacturer before or after importation; and (3) internal memory
(both read-only memory ("ROM") and read-write random access
memory ("RAM")) for word processing.

In addition, word processors may include one or more of the
following features: (1) an auxiliary memory storage device,
whether internal (e.g., RAM storage) and/ or external (e.g.,
which accepts floppy diskettes, RAM cards, or other nonvolatile
media); (2) software/ firmmware designed or modified for use
exclusively on a line of word processors (e.g., a spreadsheet or
word processing-assist program); (3) an interface permitting the
transfer of information to other word processors,
telecommunication links, computers, and the like; and (4) a type
mode, which permits the word processor to function as a
typewriter by typing characters directly onto paper. However,
the inclusion or exclusion of one or more of these features from
a word processor is not dispositive as to whether merchandise is
within the scope of this investigation.

All word processors included within the scope of this
investigation contain the following three units: (1) a keyboard
for the entry of characters, numerals and symbols; (2) a video
display; and (3) a chassis or frame containing the essential word
processing features listed above. These units may either be
integrated into one word processing system or be combined by the
user into one working system. Word processors may include, as a
fourth unit, a printer with a platen (or equivalent text-to-paper
transfer system) and printing mechanism to permit the printing of
text on paper. However, word processors which do not include a
printer as one of the major units are also included wintin the
scope of the investigation.

Word processors may be imported as integrated systems, or the
major finished units may be imported separately. With respect to
major finished units, only the major finished units listed above
are covered by this investigation. Keyboards and chassis/ frames
are included in this investigation if they are designed for use
in word processors. Printers and video displays are included in
this investigation only if they are dedicated exclusively for use
in word processors.

Major finished units are distinguished from parts or
subassemblies in that they do not require any additional
manufacturing before functioning as a complete unit of a word
processor. Neither parts nor subassemblies are included in the
scope of this investigation.

Word processing devices which meet all of the following criteria
are excluded from the scope of this investigation: (1) easily
portable, with a handle and/ or carrying case, or similar
mechanism to facilitate its portability; (2) electric, regardless
of source of power; (3) comprised of single,integrated unit; (4)
have a keyboard embedded in the chassis or frame of the machine;
(5) have a built-in printer; (6) have a platen to accommodate
paper; and (7) only accommodate their own dedicated or captive
software. (See also Final Scope Ruling: Portable Electronic
Typewriters from Japan (55 FR 47358, November 13, 1990).)

Specifically excluded from the scope of this investigation are
automatic typewriters with one- or two-line displays.

Also excluded from the scope of this investigation are personal
computers ("PCs"), including those PCs which are capable of word
processing. PCs are a class of automatic data processing
machines. Unlike automatic data processing machines, word
processing machines cannot make the logical decision during
processing to modify the execution of a program, i.e., the user
of a word processor cannot use the word processor to create new
software or to modify the program code of existing computer
programs. PCs are also distinguished from the word processors
subject to this investigation by reason of their operating
systems, which are capable of running a variety of
"off-the-shelf" software programs installed by the purchaser. In
addition, PCs generally have significantly higher memory storage
capacities and often contain major finished units which are
interchangeable with units manufactured by several producers.

Office typing systems are specifically excluded from the scope
of this investigation by virtue of the ITC determining that there
is no injury with respect to that like product. Word processors
are currently classified under HTS subheading 8469.10.00. The
video displays covered by this order are currently classified
under HTS subheading 8473.10.00107. Although the HTS
subheadings are provided for convenience and customs purposes,
our written description of the scope of this proceeding is
dispositive.

3.For further reporting purposes, this investigation has been
assigned investigation number A-588-818. The Customs
Identification numbers (below) are to be used for Customs
identification purposes and blue line reports.

4.For exports of all personal word processors from Japan, the
U.S. Customs Service shall continue to suspend liquidation of
such personal word processors that are entered or withdrawn from
warehouse on or after April 22, 1991, and shall require a cash
deposit on entries filed on or after August 28, 1991, equal to
the "weighted average margin percentage" listed below:

MANUFACTURER/ PRODUCER/ CUSTOMS ID NOWEIGHTED AVERAGE
EXPORTERMARGIN PERCENTAGE

Brother Industries, A-588-818-001 58.71
Ltd.
Kyushu Matsushita A-588-818-002 58.71
Electric Co., Ltd.
All Others A-588-818-000 58.71

7.On August 19, 1991, the International Trade Commission
notified the Department that imports of office typing systems are
not materially injuring, or threatening material injury to, a
U.S. industry. Accordingly, suspension of liquidation should be
terminated for all entries of office typing systems from Japan
that were entered, or withdrawn from warehouse, for consumption,
on or after April 22, 1991. All bonds and estimated duties
deposited on entries of these typing systems should be refunded.
(Further clarification on the above is forthcomming.)

8.If there are any questions regarding this matter by Customs
Officers, they should be referred to the Import Specialist
Division, Other Agency Branch, Customs Headquarters
(FTS 566-8561), or by E-Mail to attribute "HQ OAB". The
importing public and other interested parties should contact
Stephanie Hager or Ross Cotjanle of the Office of Antidumping
Investigations, Import Administration, International Trade
Administration, U.S. Department of Commerce, Telephone: (202)
377-5055 or 377-3534, respectively.

9.There are no restrictions on disclosing the above
information.

Nancy McTiernan