CLA-2-84:RR:NC:1:110 D85371
Mr. James Shaw
Panasonic Logistics Company of America
2 Panasonic Way
Secaucus, NJ 07094
RE: The tariff classification of Panaboards and interface units
from Japan
Dear Mr. Shaw:
In your letter dated December 7, 1998, you requested a
tariff classification ruling.
The merchandise under consideration involves three models of
Panaboards (KX-B530, KX-B630, and KX-B730) and two models of
Interface units (KX-B091 PC interface, and KX-B09 printer
interface) that are used with the Panaboard units.
The three models of Panaboards are basically electronic
whiteboards that are designed for writing information unto the
board at lectures and conferences, and then have the ability to
copy and print out the information, and even store, fax and
network the information by computer. The KX-B530 and KX-B730 are
both approximately 3 feet by 4 1/2 feet in size, while the model
KX-B630 is 3 feet by 6 feet in size. Although these Panaboards
can function as an independent print board without the use of a
computer, they are designed and marketed to function primarily as
a computer input/output printer unit. All three of the models
use a CCD image sensor, thermal print head as its copying system.
The three models of Panaboards are performing not only a
copy/print function, but appear to be principally designed and
used as a display, storing, fax, or networking device with a
computer. It is thus a composite good, whose principal function
would appear to be for computer input/output functions.
In order to utilize the Printer or PC interface, the user
must use the optional interface cards. The cards are attached to
a connector on the internal scanner located in an opening under
the Panaboard. Proprietary software must also be installed to
operate the computer functions. The KX-B09 printer interface
kit, that allows the user to transfer the data directly to a
laser printer, which consists of one proprietary interface board,
interface cable, manual and registration card, when separately
shipped, would meet the definition of a "set" as per GRI-3 (b).
The essential character of this set would be exemplified by the
proprietary interface board.
The model KX-B091 PC interface kit consists of one
proprietary interface board, one interface cable, one 3.5 1.44 MB
floppy disk, and manual. This kit allows the Panaboard to scan
the images on the screen of the Panaboard in the Microsoft
Windows operating system environment, display the images, and
print the images which have been saved. The essential character
of this set would also be the proprietary interface board.
The applicable subheading for the three models of Panaboard
units will be 8471.60.1095, Harmonized Tariff Schedule of the
United States (HTS), which provides for combined input/output
units. The rate of duty will be free.
The applicable subheading for the two interface kits, when
separately shipped, will be 8473.30.1000, HTS, which provides for
parts and accessories of the machines of heading 8471; printed
circuit assemblies. The rate of duty will be free. The
proprietary software disks, noting Legal Note 6 to Chapter 85 of
the HTS, would be separately classified under HTS number
8524.99.6000. The rate of duty will be 1.3 cents per square
meter of recording surface. Effective January 1, 1999, the rate
will be free of duty.
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