CLA-2-84:OT:RR:NC:N1:118
Mr. Jean-Claude Excoffier
HP Inc.
150 Route du Nant d'Avril
Meyrin CH1217
Switzerland
RE: The tariff classification of an inkjet printing system and its separate components from multiple counties.
Dear Mr. Exfoffier:
In your letter dated August 15, 2018, you requested a tariff classification ruling on a HP PageWide C500 Press when shipped as a complete printing system. You also requested the classifications of the units that make up the system when imported individually. The country of origin of the printing system and its units is stated to be from multiple countries, none of which include China.
The HP PageWide C500 Press is a wide format inkjet printer which is capable of printing on coated and uncoated papers, using special water-based ink formulation. It is capable of connecting to an automatic data processing unit or to a network.
The HP PageWide C500 Press is comprised of separate units connected through power, control and communication cables. You have listed the units, along with their descriptions and functions, as follows:
HP C500 Print system (PN CX200A) is the core element of the HP PageWide C500 Press, performing the initial printing task through the print heads.
HP C500 1.5m stacks - 2 lifts set (PN CP457A) or HP C500 1.8m stacks - 2 lifts & UG kit (PN CP458A) are connected to the feeder and to the stacker. The first lift is used to load the media to the feeder and from there move it to the print engine. The second lift is used to make sure that the media (coated with varnished) is removed from the stacker. In both cases the height of the lift is changed according to number of media located on it.
HP C500 2 lift conveyers set (PN CP459A) are conveyers connected to the top of the lifts. They are used to upload the media to be printed in the print system and to move the media to the stacker once printed.
HP C500 CMYK Ink Farm assembly (PN CP460A) is the ink delivery system with ink tanks, connected to the Print System.
HP C500 Production Prime Print Server (PN CP461A) is a computer used to manage and control the printing process.
HP C500 Engine Communication Module (PN CP462A) is a high-performance dual radio wireless and wired access point. It is used to provide network access for the C500 Printer.
HP C500 Standard Dryer (PN CP463A) is used to dry the ink on the printed media after the printing operation
HP C500 O.P.V. - Over Print Varnish (PN CP464A) is used for coating the printed media with varnish.
HP C500 Stacker & Media Eject unit (PN CP465A) is a stacker used to receive the printed media from the conveyor.
HP C500 Print Engine Chiller unit (PN CP466A) is used to cool the print heads.
When assembled together, the units constitute a functional printing unit.
You suggested classifying the HP C500 Production Prime Print Server (PN CP461A), when imported separately, within 8471.50.0150, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Automatic data processing machines and units thereof… Processing units other than those of subheading 8471.41 or 8471.49, whether or not containing in the same housing one or two of the following types of unit: storage units, input units, output units: Other.” However, you have stated that the Print Server controls the dryer operation, the conveyor, and safety functions. Based on the information provided, the Print Server is not merely a data connection where print jobs are formulated and dispensed, but rather a controller that governs the various processes of large scale printing operations. As such, the Print Server is performing a function beyond data processing and classification in 8471.50.0150, HTSUS, is not applicable.
You suggested classifying the HP C500 O.P.V. - Over Print Varnish (PN CP464A) as parts and accessories for printers in subheading 8443.99, Harmonized Tariff Schedule (HTS). Per the information provided, the O.P.V resembles the calendering machines described in the Harmonized System Explanatory Notes to heading 8420. Note 2 to Chapter 84, HTSUS, states that a machine which answers to a description in one or more of the headings 8401 to 8424 and at the same time to a description in one or more of the headings 8425 to 8480 is to be classified under the appropriate heading of the former group and not the latter. Inasmuch as the O.P.V is described in both heading 8420 and heading 8443, the dictates of note 2 to Chapter 84, HTSUS, preclude classification within heading 8443, HTSUS.
You suggested classifying HP C500 Standard Dryer (Part number CP463A) as parts and accessories for printers in subheading 8443.99, Harmonized Tariff Schedule (HTS). The HP C500 Standard Dryer is a machine used to dry ink on the printed media after printing operation. In the information provided, the dryer is described as having heating units. The units circulate hot air, causing evaporation and the drying of the ink.
“Parts” are classified in accordance with Note 2 to Section XVI, which states that, subject to certain exclusions found in Note 1 to Section XVI, Note 1 to Chapter 84 and Note 1 to Chapter 85, parts of machines (not being parts of the articles of heading 8484, 8544, 8545, 8546 or 8547) are to be classified according to the following rules:
(a) Parts which are goods included in any of the headings of chapters 84 and 85 (other than headings 8409, 8431, 8448, 8466, 8473, 8487, 8503, 8522, 8529, 8538 and 8548) are in all cases to be classified in their respective headings;
(b) Other parts, if suitable for use solely or principally with a particular kind of machine, or with a number of machines of the same heading (including a machine of heading 8479 or 8543) are to be classified with the machines of that kind or in heading 8409, 8431, 8448, 8466, 8473, 8503, 8522, 8529 or 8538 as appropriate. However, parts which are equally suitable for use principally with the goods of headings 8517 and 8525 to 8528 are to be classified in heading 8517;
(c) All other parts are to be classified in heading 8409, 8431, 8448, 8466, 8473, 8503, 8522, 8529 or 8538 as appropriate or, failing that, in heading 8487 or 8548.
In this instance, the dryer uses heat and evaporation to complete a drying process. Machines or machinery that treat materials by a process involving a change of temperature, such as heating, evaporating, or drying, other than machinery used for domestic purposes are specifically provided for in heading 8419. Therefore, in accordance with Note 2(a) to Section XVI, the HP C500 Standard Dryer is not classified as a part or accessory of a printer within subheading 8443.99, HTS
The applicable subheading for the HP C500 Standard Dryer, part number CP463A, will be subheading 8419.39.0180, HTSUS, which provides for Machinery, plant or laboratory equipment, whether or not electrically heated(excluding furnaces, ovens and other equipment of heading8514), for the treatment of materials by a process involving a change of temperature such as heating, cooking, roasting ,distilling, rectifying, sterilizing, pasteurizing, steaming, drying, evaporating, vaporizing, condensing or cooling, other than machinery or plant of a kind used for domestic purposes; instantaneous storage water heaters, nonelectric; Dryers; Other; Other. The general rate of duty is free.
The applicable subheading for the HP C500 O.P.V. - Over Print Varnish (PN CP464A), when imported separately, will be 8420.10.9080, HTSUS, which provides for Calendering or other rolling machines, other than for metals or glass, and cylinders thereof; parts thereof: Calendering or other rolling machines: Other: Other. The general rate of duty will be free.
The applicable subheading for the HP PageWide C500 Press, when shipped as a complete printing system, and the HP C500 Print system (PN CX200A), when shipped separately, 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 general rate of duty will be Free.
The classification of the HP C500 1.5m stacks - 2 lifts set (PN CP457A), HP C500 2 lift conveyers set (PN CP459A), HP C500 CMYK Ink Farm assembly (PN CP460A) and the HP C500 Stacker & Media Eject unit (PN CP465A) will be 8443.99.2550, Harmonized Tariff Schedule of the United States (HTSUS), which provides for printing machinery…other printers…: parts and accessories: other: parts and accessories of printers: other: other. The general rate of duty will be free.
The classification of the HP C500 Engine Communication Module (PN CP462A) will be 8517.62.0050, HTSUS, which provides for Telephone sets…; other apparatus for the transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network…: Other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network): Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other. The general rate of duty will be free.
The classification of the HP C500 Production Prime Print Server, PN CP461A, will be 8537.10.9170, HTSUS, which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of 8535 or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Other”. The general rate of duty will be 2.7 percent ad valorem.
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 the World Wide Web at https://hts.usitc.gov/current.
Your inquiry does not provide enough information for us to give a classification ruling on the HP C500 Print Engine Chiller unit (PN CP466A). Your request for a classification ruling should include the following:
Provide a step by step description detailing how air and liquid cooling is achieved.
Is a coil or heat exchanger involved in the liquid cooling process?
Is the chiller part of the HVAC unit?
Submit an exploded cutaway of the chiller with all its internal/external components identified.
When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.
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