CLA-2-84:RR:NC:1:110 C80900

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 an ink jet printer from Japan.

Dear Mr. Grace:

In your letter dated October 16, 1997, on behalf of Canon Computer Systems, Inc., you requested a tariff classification ruling.

The merchandise under consideration involves the classification of a BJC-7000 Series Color Bubble Jet Printers which will be imported without a print head unit. These printers are designed for use as computer output units.

The BJC-7000 Series Color Bubble Jet Printers are capable of printing in black and white or color. There are three basic ink cartridges that can be installed in the BJC-7000 Series Color Bubble Jet Printers. These cartridges are the BC-60 Black BJ Cartridge, the BC-61 Color BJ Cartridge, and the BC-62 Photo BJ Cartridge.

The BC-60 Black BJ Cartridge incorporates a bubble jet print head and a black ink reservoir. The print head contains 608 nozzles. The BC-61 Color BJ Cartridge incorporates a bubble jet print head and a replaceable ink tank (the BCI-61 Color Tank). The print head for the BC-61 Color BJ Cartridge contains 240 nozzles (80 nozzles for each color). The BC-62 Photo BJ Cartridge also incorporates a bubble jet print head and a replaceable ink tank (the BCI-62 Photo BJ Tank). The print head for the BC-62 Photo BJ Cartridge contains 480 nozzles (80 nozzles for each color).

All of the cartridges utilize the same technology. Each nozzle on the print head units 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.

The BJC-7000 Series Color Bubble Jet Printers will be imported in a partially assembled format. Specifically, the print head units will not be installed in the machines. The printers and ink cartridges, which contain the print head units, will be shipped separately to the United States. Therefore, at the time of importation, the BJC-7000 Series Color Bubble Jet Printers will not be fully assembled, since they are missing the print head unit.

Noting Legal Note 5(B) to Chapter 84 of the HTS, these BJC-7000 Series Color Bubble Jet Printers, would meet the definition of a "unit" of an ADP system. NY Ruling Letters 813779 and NY 812454 are the subject of similar color bubble jet printers.

The applicable subheading for the BJC-7000 Series 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
Director,
National Commodity
Specialist Division