CLA-2-84:RR:NC:1:110 B88377

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 Canon BJC-80 color bubble jet printer from Japan.

Dear Mr. Grace:

In your letter dated April 11, 1997, on behalf of Canon Computer Systems, Inc., you requested a tariff classification ruling.

The merchandise under consideration involves a model Canon BJC-80 color bubble jet printer that will be shipped with the BJ ink cartridges not assembled with the printer.

The BJC-80 bubble jet color printer is designed for use as a computer output unit and is capable of printing in black and white or color. Two different cartridges may be installed in the BJC-80; the BC-11e color BJ cartridge and the BC-10 black cartridge. Only one cartridge is installed at any time, thus the user needs to change cartridges depending on his printing needs. The BC-11e color cartridge incorporates a bubble jet print head and four ink reservoirs, containing black, cyan, magenta, and yellow ink. The print head for the BC-11e color BJ cartridge contains a total of 136 nozzles- 64 nozzles for black and 24 nozzles for each of the three colors.

Both cartridges utilize the same technology. Each nozzle on the print head 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 media, the expelled ink forms a contrasting dot. The selective printing of dots results in the final image.

The BJC-80 printer has a resolution of 720 x 360 dpi, and prints at 2 ppm with color, and 4.5 ppm with black. It incorporates an IEEE 1284-compatible parallel interface, and weighs approximately 3.1 pounds. It has dimensions of 11.8 inches in width, 6.2 inches in depth, and 2.2 inches in height.

Noting Legal Note 5 (B) to Chapter 84 of the HTS, the BJC-80 printer would meet the definition of a "unit" of an ADP system. Although the printer and BJ ink cartridges will be shipped in the same carton, the cartridges will be detached from the printer assembly and enclosed in a sealed plastic container. Thus in their imported condition the printers do not represent assembled printers. Please note also New York Ruling letters B86969 and B86966 which involved similar merchandise.

The applicable subheading for the BJC-80 color bubble jet printer will be 8471.60.6400, 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 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