CLA-2-84:RR:NC:1:110 I85533
Ms. Lydia E. Lorenzo
Ricoh Corporation
Five Dedrick Place
West Caldwell, NJ 07006
RE: The tariff classification of parts for a duplicator and a copier from Japan.
Dear Ms. Lorenzo:
In your letter dated August 14, 2002, on behalf of Ricoh Corporation you requested a tariff classification ruling.
The merchandise under consideration is two metal rear drum flange supports, one for a duplicator (Part Number C2184565) and one for an analog copier (Part Number AD014020). Samples of the two flange supports were submitted with your ruling request and will be returned to you. The rear drum flange support for the duplicator (Part Number C2184565) is a round metal rim with three spokes; a gear is attached to the center of the spokes. Two of these flange supports slide onto the drum shaft and support the metal screen drum of a duplicator. The gear on the drum flange support serves as the drive mechanism to turn the cylindrical drum. The rear drum flange support for the analog copier (Part Number AD014020) is a round metal casting with a machined shaft housing, there are shaft bearings pressed into both ends of the shaft housing. This flange support slides onto the drum shaft and supports the drum and heater.
Both items perform the same function but are for two separate types of machines that are classified under two different headings. The duplicator would fall under heading 8472 while the analog copier would fall under heading 9009 of the HTS. These flange supports slide onto a shaft and support the drum for a duplicator and analog copier. The duplicator (Part Number C2184565) flange support consists of more than a simple gear since it completes part of a drum assembly. Likewise, the analog copier (Part Number AD014020) flange support consists of more than a simple shaft housing with bearings, as it also completes part of a drum assembly.
Classification of parts is determined by Legal Note 2 to Section XVI, Harmonized Tariff Schedule of the United States (HTS), which states “Subject to note 1 to this section, note 1 to chapter 84 and to note 1 to chapter 85, parts of machines…are to be classified according to the following rules:
Parts which are goods included in any of the headings of chapters 84 and 85…are in all cases to be classified in their respective headings;
Other parts, if suitable for use solely or principally with a particular kind of machine, or with a number of machines of the same heading…are to be classified with the machines of that kind…as appropriate….
All other parts are to be classified in heading 8409, 8431, 8448, 8466, 8473, 8503, 8522, 8529 or 8538 as appropriate or, failing that, in heading 8485 or 8548.”
Noting Legal Note 2(b) to Section XVI of the HTS, the rear drum flange support for a duplicator (Part Number C2184565) is designed and principally used with machines of heading 8472.
The applicable subheading for the duplicator rear drum flange support (Part Number C2184565) will be 8473.40.8500, Harmonized Tariff Schedule of the United States (HTS), which provides for “Parts and accessories…for use solely or principally with machines of headings 8469 to 8472: Parts and accessories of the machines of heading 8472: Other.” The rate of duty will be 1.9% ad valorem.
Legal Note 2(b) to Chapter 90 of the HTS states “Other parts and accessories, if suitable for use solely or principally with a particular kind of machines, instrument or apparatus…are to be classified with the machines, instruments or apparatus of that kind.”
The applicable subheading for the analog copier rear drum flange support (Part Number AD014020) will be 9009.99.8070, Harmonized Tariff Schedule of the United States (HTS), which provides for “Photocopying apparatus incorporating an optical system or of the contact type and thermocopying apparatus; parts and accessories thereof: Parts and accessories: Other: Other: Parts and accessories of other photocopying apparatus.” 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 Eileen S. Kaplan at 646-733-3016.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division