CLA-2 RR:CTF:TCM W967921 TPB
Sandra Liss Friedman
Barnes, Richardson & Colburn
475 Park Avenue South
25th Floor
New York, NY 10016
RE: Brother PT-2600; GRI 3(b) sets; Customs Directive 099-3550-061; NY L87307;
Dear Ms. Friedman:
This is in regard your letter of September 27, 2005, on behalf of your client, Brother International Corporation (“Brother”) requesting confirmation of your interpretation of Customs Directive 099 3550-061, dated September 18, 1992, and its application to your clients product, the Brother PT-2600 labeling machine and certain accessories for the labeling machine. We regret the delay in responding to you.
The PT-2600 labeling machine, along with four other models of P-Touch labeling machines, was the subject of New York Ruling Letter L87307 (September 19, 2005). That ruling letter classified the PT-2600 under subheading 8471.60.6500, HTSUS, as “Automatic data processing machines and units thereof… Input or output units… Other: Printer units: Other: Thermal transfer.” The PT-2600 will be imported packaged ready for retail sale in the following configuration:
PT-2600 labeling machine
Starter tape cassette
Address label cassette
CD Rom
USB cable
Batteries
Tape separator
Printed materials
It is your contention that the articles in the above set which are of nominal value or do not have any direct role to perform in carrying out the functioning of the PT-2600 labeling machine, and therefore do not determine the rate of duty that the set carries, need not be reported on a separate line item on the entry, provided that the value of such items is included in the declared value of the set. These articles would include the USB cable, batteries, CD Rom, tape separator and printed materials.
The Office of Regulations and Rulings is not in a position to issue a ruling to you on this matter. Your inquiry addresses issues subject to a field directive. Inquiries as to entry procedures should be directed to Ms. Sherri Hoffman, Chief, Entry and Drawback Management, Office of Field Operations.
Sincerely,
Gail A. Hamill, Chief
Tariff Classification and Marking Branch