CLA-2-84:RR:NC:1:110 D85703
Ms. Sandra Liss Friedman
Barnes, Richardson & Colburn
475 Park Avenue South
New York, N.Y. 10016
RE: The tariff classification of computer label printers from
Japan.
Dear Ms. Friedman:
In your letter dated December 7, 1998, on behalf of Brother
International Corp., you requested a tariff classification
ruling.
The merchandise under consideration involves the model PT-2500PC and the model PT-9200PC P-TouchPC computer label printers
which operate as output units for personal computers to create
customized adhesive backed labels.
These P-Touch PC label printers are compatible with any
personal computer that operates in a Microsoft Windows or
Macintosh environment. After a customized label is designed on
the personal computer, the P-TouchPC prints out the label using a
thermal transfer printhead. The PT-9200PC is a more upscale
version of the PT-2500PC. It is capable of printing at a higher
resolution and in more print fonts and sizes. The PT-9200PC
will be marketed for the commercial user whereas the PT-2500PC
market will be for the home office user. The units are connected
to a personal computer through a serial interface cable.
The P-Touch PC label printer tape cassettes contain three
spools of different printing media materials. One of the spools
contains the adhesive plastic tape onto which the letters or
designs are printed. This tape actually acts as the finished
label after it is printed and peeled from its paper backing. A
second spool contains the colored plastic tape which is the
"inked" material which prints onto the plastic label. The inked
ribbon is then rewound inside the cartridge. The third spool
contains a clear plastic strip which covers the colored tape
which is printed onto the adhesive label. These printers are
imported without the assembly of a tape cassette, and are thus
considered to be unassembled printers. The tape cassette is
always packaged separately, but shipped in the same shipping
carton.
The P-TouchPC computer label printers are similar to other
label printers that are used in conjunction with computer output
units. Labeling machines which operate via a commuter interface
were the subject of NY Ruling Letters 898221 and 875724. These
P-TouchPC computer label printers also meet the definition of
automatic data processing machine units as per Legal Note 5(B)
and 5(D) of Chapter 84 to the HTS.
The applicable subheading for the model PT-2500PC and the
model PT-9200PC P-TouchPC computer label printers will be
8471.60.6500, Harmonized Tariff Schedule of the United States
(HTS), which provides for other thermal transfer printers. 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
Director,
National Commodity
Specialist Division