CLA-2-84:S:N:N1:110 805805
Mr. William D. Outman, II
Baker & McKenzie
815 Connecticut Avenue, N.W.
Washington, D.C. 20006-4078
RE: The tariff classification of an HP OfficeJet Integrated
Printer-Fax-Copier from Singapore.
Dear Mr.Outman:
In your letter dated January 10, 1995, on behalf of
Hewlett-Packard Company, you requested a tariff classification
ruling.
The merchandise under consideration involves a
multifunctional office machine that combines a printer, plain
paper facsimile, and a convenience copier in a single unit.
The H-P OfficeJet printer component includes an inkjet
printer featuring 600 x 300 DPI resolution; compatibility with
the H-P DeskJet 500/510/520 printers; ability to handle different
sizes of paper; transparencies and envelopes; and a print speed
of up to three pages per minute. This machine uses the same H-P
inkjet print mechanism as the H-P Deskjet printer uses. This
machine includes a printer driver for Windows and leading MS-DOS
applications, and incorporates a Parallel Centronics interface
for connection to a personal computer.
The OfficeJet fax component provides the consumer with 65
speed-dial numbers; a 20-page automatic document feeder; a 24-
page memory which stores faxes that are received when the machine
is out of paper or ink, or when it is printing; and the ability
to share a single phone line. In its condition as imported
however, the OfficeJet will not have a "line interface unit
(LIU)," making it impossible to use the fax. The LIU will be
added during final assembly and inspection prior to packaging for
sale to users.
The OfficeJet convenience copier component produces up to 99
unattended copies at a rate of 50 seconds per page and has six
reduction capabilities (from 100% to 75% in 5% increments).
Although this machine can perform as a fax and as a copier,
it appears to be most frequently used as a printer. The machines
high DPI resolution and fast printing speed, and the importer's
marketing strategy that emphasizes the printer function, leads us
to believe that this composite machine will be principally used
as an ADP output printer. The copier function is extremely slow
and appears to be primarily a convenience feature.
Noting Legal Note 3 to Section 16 of the HTS, this
multifunction machine appears to be principally designed and used
for printing functions. Note also NY Ruling letter 897228 and
804946 which ruled on similar multifunctional printers.
The applicable subheading for the HP OfficeJet machine will
be 8471.92.4400, Harmonized Tariff Schedule of the United States
(HTS), which provides for assembled ink jet printers,
incorporating at least the media transport, control and print
mechanism. The rate of duty will be 3 percent ad valorem.
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
transaction.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport