CLA-2-84:RR:NC:1:110 B84344
Mr. Raymond Valdes
Ricoh Corporation
Five Dedrick Place
West Caldwell, N.J. 07006
RE: The tariff classification of multifunction
printer/copier/scanner units from Japan.
Dear Mr. Valdes:
In your letter dated April 9, 1997, you requested a tariff
classification ruling.
The merchandise under consideration involves the Ricoh
Aficio Color 2000, 5000, and NC Series of Digital Color
Copier/Printer/Scanner units. The Ricoh Aficio Color Series
2003, 2103, 2203, 5106, 5206, and NC8115 are multifunction
digital color copier/printer and scanner print servers. These
units in their configuration connected to a Fiery XJ Color server
allows these devices to act as printer on a network supporting
multiple computer platforms. These platforms include personal
computers, Mac, and Unix workstations such as Silicon Graphics
and Sun Sparc workstations.
These engines are Raster Output devices which are capable of
scanning hardcopy originals to create a master or "Digital
Original". These digital originals can then reproduce through
its electrophotographic process (laser print engine) to produce
full color or black and white prints.
The Ricoh Aficio Color Series 2000, 5000, and NC8115 are all
multifunction devices that consist of a single unit which
incorporate electrostatic photocopying and laser automatic data
processing (ADP) output function. The laser printer and
photocopying functions share a single electrostatic imaging
system which produces images by adhering color toners to plain
paper by means of a photoconductor drum.
The Ricoh Aficio Color Series 2000, 5000, also feature
digital scanning, which is used in connection with document
production and document creation. The scanner serves as an input
device allowing document images to be scanned electronically.
The digital file can be sent electronically through most networks
allowing multiple users to print their files both color and black
and white from any designated Aficio color print engine.
The Ricoh Aficio Color Series 2003, 2103, 2203, 5106, 5206,
and NC8115 all meet the definition of a composite good made up of
different components which are described in different provisions
of the HTS. It is noted that similar multifunctional printers
were the subject of various NY Ruling Letters, and recently were
the subject of NY A81130 and NY A88887. These multifunction
printer units also meet the definition of a "unit" of an ADP
machine system as noted in Legal Note 5(B) of Chapter 84, HTS.
Although these models are capable of use as digital photocopiers,
their principal use appear to be as digital ADP output printers.
The Ricoh Aficio Color 5000 Series color copies print up to
31 pages per minute in black and white or 6 prints per minute in
color. The Ricoh Aficio Color 2000 Series prints up to 21
prints per minute in black and white or up to 3 prints per minute
in color. The NC8115 prints up to 15 pages per minute in both
black and white and full color.
The Ricoh Aficio Color Digital Color Copier, Printer/Scanner
Units are also similar to the merchandise which is the subject of
NY Rulings 817475 and A80061.
In some instances Ricoh Corporation may import the Ricoh
Aficio Color Series with the printer interface PCB, the interface
harness and the pre-transfer lamp unit removed, packaged
separately, and over-packed with the device.
The applicable subheading for the Ricoh Aficio Color 2000,
5000 series, and NC8115 of Digital Color Copier/Printer/Scanner
units when imported in a fully assembled unit will be
8471.60.5200, Harmonized Tariff Schedule of the United States
(HTS), which provides for other laser printer units, assembled,
incorporating at least the media transport, control, and print
mechanism. The rate of duty will be 1.5 percent ad valorem.
The applicable subheading for the Ricoh Aficio Color 2000,
5000 series, and NC8115 of Digital Color/Printer/Scanner units
when imported with the printer interface PCB, the interface
harness and the pre-transfer lamp removed, packaged separately,
and over-packed with the device will be 8471.60.6200, HTS, which
provides for other laser printer units. 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 Art
Brodbeck at 212-466-5490.
Sincerely,
Robert B. Swierupski
Chief, Metals & Machinery Branch
National Commodity
Specialist Division