CLA-2-84:RR:NC:1:110 C80114
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 Canon BJC-4300 series color bubble jet printer from Japan.
Dear Mr. Grace:
In your letter dated September 30, 1997, on behalf of Canon Business Machines, you requested a tariff classification ruling.
The merchandise under consideration involves the Canon series of BJC-4300 color bubble jet printers when shipped in the same carton as detached printing mechanisms, and thus not fully assembled.
The BJC-4300 series of bubble jet printers currently includes the following three models: the BJC-4300; the BJC-4302; and the BJC-4304, all of which are designed to be used as computer output units, and capable of printing in black and white and color. Two types of basic ink cartridges can be installed in the BJC-4300 series of machines: the BC-black BJ cartridge (optional), and the BC-21e color BJ cartridge (standard). All of the 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.
The BJC-4302 as an example, has a black print speed of up to 5 ppm, and up to 2 ppm for color. It has a print resolution of 720 x 360 dpi, and standard emulation that includes Canon extended mode, Epson LQ 2550 and IBM X24E. It is basically a desk-top computer output printer. Although the printer and BJ ink cartridges will be shipped in the same carton, the cartridges will be detached from the printer assembly and enclosed in a sealed container. The BJ ink cartridge will not be installed in the printer until after the unit has been purchased by a retail customer in the United States.
Noting Legal Note 5 (B) to Chapter 84 of the HTS, and NY Ruling B86966, the BJC-4300 series of printers would meet the definition of a "unit" of an ADP system. Although the printer and BJ ink cartridges will be shipped in the same carton, the cartridges will be detached from the printer assembly and enclosed in its own sealed container. Thus in their imported condition the printers do not represent "assembled" printers. Please note also NY Ruling letter B88377 which involved a similar issue.
The applicable subheading for the BJC-4300 series color bubble jet printer 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 Art Brodbeck at 212-466-5490.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division