CLA-2-84:RR:NC:1:110 D83998
Mr. Raymond A. Valdes
Ricoh Corporation
Five Dedrick Place
West Caldwell, N.J. 07006
RE: The tariff classification of multifunctional
printer/copier/fax units from Japan.
Dear Mr. Valdes:
In your letter dated October 20, 1998, you requested a
tariff classification ruling.
The merchandise under consideration involves three models of
multifunctional printer/copier/fax units which are known as the
Gestetner 3220, 3225, and 3240. These digital imaging machines
can be connected to a printer controller which enables these
units to function within the framework of a local area network or
client server workgroup environment with printer server.
The Gestetner 3220 and 3225 produce digital black and white
output at 600 by 600 dots per inch (dpi), with up to 64
graduations per dot. They weigh 127 pounds each and use laser
print engines that utilize an electrophotographic process. The
Gestetner 3220 prints up to 20 pages and the 3225 prints up to 25
pages per minute. Both models utilize PCL 5e and can be upgraded
to include up to 34 MB of internal printer memory.
The Gestetner 3240 produces digital and white output at
600/400/300 dots per inch (dpi), with up to 256 graduations per
dot. It prints up to 40 pages per minute with 8 « inch by 11
inch paper at 300 or 400 dpi, or 20 pages per minute with 8 «
inch by 11 inch paper at 600 dpi. The three models have
automatic paper feeders, and have a total paper capacity of 3,100
sheets for the Gestetner 3220, 2850 sheets for the Gestetner
3225, and finally 3500 sheets for the Gestetner 3240. These
units are capable of printing on various paper sizes, and have a
maximum paper capacity of 11 inches by 17 inches.
These machines are capable of performing printing, copying,
and facsimile functions, and are in one common housing. They all
meet the definition of a composite good made up of different
components which are described under different provisions of the
HTS. Noting GRI-3(b) to the HTS, these composite goods would
thus be classified as if they consisted of the material or
component which gives them their "essential character". Noting
their high print speed and the fact that these units are the most
efficient as networked printers, they would appear to have an
"essential character" of a networked automatic data processing
machine document printer.
These models are also similar to other multifunctional
printer/copier/fax machines which were the subject of NY Rulings
D82304 and NY C83939. These models also meet the definition of a
"unit" of an ADP system, as per Legal Note 5(B) to Chapter 84 of
the HTS.
The applicable subheading for the Gestetner 3225 and 3240
units will be 8471.60.5100, Harmonized Tariff Schedule of the
United States (HTS), which provides for laser printers units,
capable of producing more than 20 pages per minute. The rate of
duty will be free.
The applicable subheading for the Gestetner 3220 multi-
functional printer will be 8471.60.5200, HTS, which provides for
other laser printer unit. The rate of duty will be 0.5 percent
ad valorem.
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