CLA-2-84:OT:RR:NC:N1:118
Ms. Laura Lyons
EFI, Inc.
6750 Dumbarton Circle
Fremont, CA 94555
RE: The tariff classification of industrial inkjet printers from Italy.
Dear Ms. Lyons:
In your letter dated May 23, 2016, you requested a tariff classification ruling.
Your request concerns two models of Regginiani Digitial Industrial Printers. Both of these industrial inkjet printers utilize water-based inks. They are functionally the same but differ in printing width capability, production speed, print quality and substrate medium. The model referred to as FABRIVU 180/340 can be used for printing on either fabric or paper/plastic substrates. It has a production speed up to 4,000 ft2 per hour and a resolution up to 2,400 DPI. Model ReNOIR is designed soley for fabric printing. It has a production speed up to 180 m2 per hour and a resolution up to 1200 DPI. Each printer model will be imported in one shipment with an “EFI Fiery proServer”. You have stated that the printers are digitally operated using this server, which functions as an ADP machine, and includes a monitor, mouse and touchscreen.
Legal Note 4 to Section XVI, Harmonized Tariff Schedule of the United States (HTSUS), states that: "[w]here a machine (including a combination of machines) consists of individual components (whether separate or interconnected by piping, by transmission devices, by electric cables or by other devices) intended to contribute together to a clearly defined function covered by one of the headings in chapter 84 or chapter 85, then the whole falls to be classified in the heading appropriate to that function." As imported, each Regginiani Digitial Industrial Printer consists of several components (i.e. the injet printer, the server, monitor, mouse and touchscreen ) intended to contribute together to the clearly defined function of printing. Therefore, classification within Heading 8443, HTSUS, is applicable.
The applicable subheading for each Regginiani Digitial Industrial Printer (i.e. models FABRIVU 180/340 and ReNOIR) and their respective “EFI Fiery proServer”, imported complete as a functional unit in one shipment, will be 8443.32.1040, HTSUS, which provides for Printing machinery used for printing by means of plates, cylinders and other printing components of heading 8442; other printers, copying machines and facsimile machines, whether or not combined; parts and accessories thereof: Other printers, copying machines and facsimile machines, whether or not combined: Other, capable of connecting to an automatic data processing machine or to a network: Printer Units: Ink jet. The rate of duty will be Free.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at https://hts.usitc.gov/current.
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 Anthony E. Grossi at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division