CLA-2-84:RR:NC:1:110 B88291
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 a multifunction Color Copier/Printer from Japan.
Dear Mr. Grace:
In your letter dated July 25, 1997, on behalf of Canon U.S.A., Inc., you requested a tariff classification ruling.
The merchandise under consideration involves a "Canon" CLC 1000 multifunctional color laser copier/printer. This device is designed to be used as the output unit for an automatic data processing system, in addition to functioning as a stand-alone digital copier.
The CLC 1000 produces digital color output at 400 x 400 dots per inch (dpi), with up to 256 graduations per color. It is also capable of printing in black and white. The CLC 1000 employs a dry laser electrophotostatic developing process. The printers utilize four separate toner drums with developer units. Each drum is dedicated to a single color.
The CLC 1000 is capable of printing at the rate of 31 pages per minute. It has an automatic paper feeder and a total paper capacity of 5,250 sheets. This device also employs digital copying and scanning capabilities. Although the CLC 1000 may be used as a "stand-alone" digital copier, it is fully capable of operating in a networked computer environment.
This CLC 100 multifunctional Color Copier/Printer appears to be principally designed for use as a color printer for ADP systems and networks. The digital copying function is a subsidiary function which also utilizes the product's laser printing components. The CLC 1000 meets the definition of a "composite good" made up of different components which are described under different provisions of the HTS. Although this device is capable of use as a digital photocopier, its principal use appears to be as an output printer for ADP machines. The CLC 1000 is also similar to the multifunction copier/printer device which were the subject of NY Ruling Letters A84115, A80061, and Headquarter's Letter 958348.
Canon U.S.A. intends to import the CLC 1000 multifunction Color Copier/Printer without the toner cartridges. In its condition as imported therefore, the Canon CLC 1000 is not an "assembled" printer as per Heading 8471.60.51.
The applicable subheading for the "Canon" CLC 1000 multifunction Color Copier/Printer will be 8471.60.6100, Harmonized Tariff Schedule of the United States (HTS), which provides for other 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 212-466-5490.
Sincerely,
Robert B. Swierupski
Chief, Metals & Machinery Branch
National Commodity
Specialist Division