CLA-2-84:S:N:N1:110 813779

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 Color Bubble Ink Jet Printer from Japan.

Dear Mr. Grace:

In your letter dated August 14, 1995, on behalf of Canon Computer Systems, Inc., you requested a tariff classification ruling. The merchandise under consideration involves a model Canon BJC-610 Color Bubble Jet Printer that will be imported without its print head unit.

Model BJC-610 Bubble Jet Printer is designed for use as a computer output unit and is capable of printing in black and white and color. It uses four replaceable ink reservoirs or cartridges. The four cartridges contain black, cyan, magenta, and yellow ink. The printer incorporates an 8-bit parallel interface, 60 KB input buffer memory, and up to 720 dpi resolution. The printer is approximately 16 inches in width, 10 inches in depth, and 7 inches in height.

These printers will be imported in a partially-assembled format since the 64 nozzle print head unit will not be included. The print head units incorporate an open-ended chamber that contains a heater. When the heater is turned on, ink is vaporized forming an air bubble. As the bubble expands, ink is expelled out of the open end of the chamber. Upon striking the print media, the expelled ink forms a contrasting dot. The selective printing of dots results in the final image. Without the print head unit, the printer cannot perform its printing functions. In its imported condition, therefore, the lack of a print head would represent a printer that is without its print mechanism.

Noting Legal Note 5 (B) to Chapter 84 of the HTS, these partially assembled printers would meet the definition of a "unit" of an ADP system. The applicable subheading for the BJC-610 Bubble Jet Printer, imported without a print head, will be 8471.92.6200, Harmonized Tariff Schedule of the United States (HTS), which provides for other printer units . 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