NY 862408
Apr 19 1991
CLA-2-84:S:N:N1:110 862408
Ms. Madeline B. Kuflik
Matsushita Electric Corporation of America
One Panasonic Way
Secaucus, New Jersey 07094
RE: The tariff classification of laser beam printers without
control units from Japan.
Dear Ms. Kuflik:
In your letter dated April 12, 1991, you requested a tariff
classification ruling.
The merchandise under consideration involves various models
of industrial grade laser beam printers that are used in the high
end of the desktop publishing field where high grade quality
printed products are produced in-house.
The printers include the following models: FP-L140XG; FP-
L140XU; FP-L140LD; FP-L140LDE; FP-L300EMU; FP-L300EMG; FP-
L301EMU; FP-L301EMG; and FP-L800, all of which are imported and
sold to OEM customers. The OEM customers add the controllers, or
more commonly called control units to the imported printers. The
function of the control unit is to convert the signal from the
computer into a language which can be understood by the printer,
and to define the format of the eventual printed page. Unlike
the ordinary office laser printer, which normally incorporates
the control mechanism, these industrial laser beam printers lack
the control mechanism upon importation, and thus are not complete
output units. These laser beam printers can print from 300 to
600 dots per inch (dpi), while office-type printers print at only
300 dpi.
The imported printers known in the trade as "engines" or
"imagesetters" can have the control units either mounted on top
of the printer, or in some cases mated as separate stand alone
control units. Since these imported models lack the control
unit, they are not complete output printers since they lack the
ability to convert signals provided by the computer into an
intelligible form.
The applicable subheading for the laser beam printers
without control units will be 8471.92.7000, Harmonized Tariff
Schedule of the United States (HTS), which provides for other
printer units. 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 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