NY 873671
MAY 04 1992
CLA-2-84:S:N:N1:105 873671
Mr. Robert S. Kirschenbaum
Kroy Inc.
P.O. Box C-12279
Scottsdale, AZ 85267-2279
RE: The tariff classification of lettering systems and parts
from Japan and Taiwan
Dear Mr. Kirschenbaum:
In your letter dated April 16, 1992 you requested a tariff
classification ruling.
You inquire about two machines for composing letters,
numbers and other symbols: the Duratype 240 and the 360 Digital
Lettering System. Your firm will import the model 240 complete
from Japan. For the model 360 you will import only printed
circuit boards; the rest will be produced in your Wisconsin
plant. You also state that you will import replacement parts for
the model 240 from Japan.
The 240 and 360 machines compose type and print characters
on an adhesive backed strip for transfer to a "paste-up" sheet or
other background for generating copy. Both machines include the
following five elements: a thermal transfer printing mechanism; a
type feed and guide mechanism; software containing font data,
font data manipulation printing algorithms and the means to
communicate said data to the thermal transfer printing
mechanism; color-carrying film and adhesive tape cassettes; and a
typewriter-type keyboard. Each model has one built-in typeface.
A variety of other typefaces in various sizes are available on
data cards. Those cards are installed to a connector via a slot
in the printer housing.
When a key on the keyboard is depressed, font data for the
selected character is buffered. The 16-character display screen
on model 240 and the 80-character one on model 360 allows one to
edit before printing. When the desired line of characters has
been selected and modified, printing is begun by depressing the
print key.
The drive mechanism then propels the color-carrying ribbon
and adhesive backed tape past the thermal print head so that the
tape and ribbon are in contact and the ribbon's non-color
carrying side contacts the print head. As the tape and ribbon
move past the print head, the previously buffered data is
communicated to the print head, turning heating elements on and
off and thus causing transfer of color material to the tape.
Model 240 prints up to 15 characters per second at a resolution
of 240 dots per inch (dpi), while model 360 prints 26 characters
per second at a resolution of 300 dpi.
After each line of composition is printed, the portion of
tape bearing it is expelled from the machine and cut. The paper
backing is then removed from the adhesive-backed film, which is
then positioned on a "paste-up" sheet for layout and
photocopying.
The applicable subheading for both the Duratype 240 and the
360 Digital Lettering System will be 8442.20.0000, Harmonized
Tariff Schedule of the United States (HTS), which provides for
machines, apparatus and equipment for typesetting or composing by
other processes, with or without founding device. This provision
is free of duty.
Parts of these machines are classifiable in accord with Note
2, Section XVI, HTS. The printed circuit boards for model 360
are not goods included in any of the headings of chapter 84 or
85, and are suitable for use only with model 360. And so, the
applicable subheading for them will be 8442.40.0000, HTS, which
provides for parts of machinery, apparatus and equipment for
type-founding or typesetting. This provision is also free of
duty.
Since you do not specify what parts of model 240 you may
import, we cannot determine their classifications. Any further
inquiry should fully describe them, including their constituent
materials.
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