CLA-2-84:R:N1:110 815407

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 an ink jet printer from Japan or Thailand.

Dear Mr. Grace:

In your letter dated September 29, 1995, on behalf of Canon Computer Systems, Inc., ("CCSI") you requested a tariff classification ruling.

The merchandise under consideration involves a Canon BJC-210 Color Bubble Jet Printer that is imported without a print head unit.

The BJC-210 Color Bubble Jet Printer is designed for use as a computer output unit, and is capable of printing in black and white or color. Two different cartridges may be installed in the BJC-210; the BC-05 Color BJ Cartridge (standard), or the BC-02 Black BJ Cartridge (optional). The BC-05 Color BJ Cartridge is specifically designed for use with the BJC-210 Bubble Jet Color Printer.

Both cartridges utilize the same technology. 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 in the final image. Without a print head unit, no printing can be performed.

CCSI will import the printers in a partially assembled format. Specifically, the print head units will not be installed in the machines at the time of importation. The printers and ink cartridges (which contain the print head units) will be shipped separately. Noting Legal Note 5 (B) to Chapter 84 of the HTS, this printer would meet the definition of a "unit" of an ADP system. Without the print head unit and ink cartridge, this printer would represent a printer that is without its print mechanism.

The applicable subheading for the Canon BJC-210 Color Bubble Jet Printer when it is imported without a print head unit (print mechanism) will be 8471.92.6200, 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 Section 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 212-466-5490.

Sincerely,

Roger J. Silvestri
Director
National Commodity
Specialist Division