CLA-2-84:RR:NC:1:103 J87763
Mr. Damon V. Pike
Deloitte & Touche LLP
Suite 1500
191 Peachtree Street, NE
Atlanta, GA 30303-1924
RE: The tariff classification of a digital dry printing system from Japan
Dear Mr. Pike:
In your letter dated August 1, 2003 on behalf of Noritsu America Corporation you requested a tariff classification ruling.
The dDP-411 digital dry printer system is used in various retail locations such as convenience and office stores, photo labs, and service bureaus to print images onto rolls of semi-gloss photo paper. The system consists of two units, the OM-1 imput workstation and the DP-400 inkjet printer, which are connected together by an electrical cable. An operator loads a CD-ROM, CD-R, SmartMedia, Memory Stick, CompactFlash, PC card or similar media containing digital images into the OM-1, enabling up to 20 thumbnail-sized images to be displayed on the workstation’s 15-inch LCD color monitor touchscreen. Using the touchscreen, the operator selects which images to print, the size of the print (the system can produce enlargements up to 12 inches by 18 inches in size), and the number of copies of each print. The operator can also make color and density corrections to the displayed images utilizing the OM-1’s keyboard. The unit can be used to copy a digital image from one type of media to another, such as from a memory stick to a CD-ROM, or to copy an existing photograph using an optional digital scanner.
The DP-400 features an inkjet print resolution of 720 by 1440 dots per inch, and utilizes seven individual color ink cartridges (cyan, magenta, yellow, black, light cyan, light magenta, and light black). It incorporates a dual roll magazine capable of holding paper rolls 100 meters long and up to 152 millimeters wide in the upper magazine and up to 305 millimeters wide in the lower one. The DP-400 can print up to 400 3 ½ inch by 5 inch pictures per hour. The dDP-411 system does not utilize a chemical-based processing system, nor is it used with an ADP machine.
In your letter you suggested classifying the dDP-411 system in subheading 9010.50.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for other apparatus and equipment for photographic laboratories: other. However, as the system does not utilize a photographic process it cannot be classified in the subheading you suggested.
The applicable subheading for the dDP-411 digital dry printing system will be 8443.51.5000, HTS, which provides for other printing machinery: ink-jet printing machinery: other. 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 Alan Horowitz at 646-733-3010.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division