CLA-2-84:S:N:N1:110 812454

Mr. David R. Grace
Covington & Burling
1201 Pennsylvania Avenue, N.W.
P.O. Box 7566
Washington, D.C. 20044-7566

RE: The tariff classification of a BJC-4100 Bubble Jet Color Printer from Mexico.

Dear Mr. Grace:

In your letter dated July 28, 1995, on behalf of Canon Business Machines, Inc., you requested a tariff classification ruling. The merchandise under consideration involves a Canon BJC- 4100 Bubble Jet Color Printer that is imported without its ink jet print head and ink cartridge.

The BJC-4100 Bubble Jet Printer is designed for use as a computer output unit and is capable of printing in black and white or color. Two different cartridges can be installed in the BJC-4100; 1. the BC-20 Black BJ cartridge, or 2. the BC-21 Color BJ cartridge. The BC-21 color cartridge incorporates a bubble jet print head and two replaceable ink tanks. The print head for the Bc-21 cartridge contains 64 nozzles for black ink and 72 nozzles for color. The BC-20 black cartridge incorporates a bubble jet print head and a black reservoir. The print head contains 128 nozzles. The printer has a print resolution of 720 x 360 dpi, a Buffer/RAM memory of 64 KB, and a standard 8-bit parallel interface.

At time of importation, the printer will not be fully assembled, since it is missing the print head unit. Noting Legal Note 5 (B) to Chapter 84 of the HTS, this printer would meet the definition of a "unit" of an ADP system. Without the print head unit and ink cartridge, this printer would represent a printer that is without its print mechanism.

The applicable subheading for the Canon BJC-4100 Bubble Jet Color Printer without its print mechanism, will be 8471.92.6200, Harmonized Tariff Schedule of the United States (HTS), which provides for other ink jet printers. The rate of duty will be free.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director
New York Seaport