CLA-2-84:OT:RR:NC:N1:106

Mr. Milton Tamamoto
Nippon Express USA, Inc.
230-19 International Airport Center Blvd.
Suite 100
Jamaica, NY 11413

RE: The tariff classification of spools of thermal transfer supply ribbon for a dye sublimation ID card printer from Japan.

Dear Mr. Tamamoto:

In your letter dated October 5, 2007 on behalf your client, Kanematsu USA, Inc., you requested a tariff classification ruling. You included a descriptive brochure and several samples with your request. The merchandise at issue is referred to as a ribbon cartridge. Several models of the same design (K1, KO1-d, 3BP, YMCK02, YMCKOK2, YMCKF), differing only in the colors or coatings that they carry, are referred to in your letter and included in your samples. The item is not in fact a cartridge but the spool of ribbon which carries the print medium. These spools, according to the information you present, replace used or expended spools of the same type within the printer cartridges used in Nisca Direct Card Printers, specifically designed for the printing of ID cards. These printers are used in connection with an automatic data processing (ADP) machine and use dye sublimation by means of heat transfer to produce the desired images on blank plastic cards.

The plastic spools are approximately four and a half inches in length overall with a smooth spindle at one end and a gear at the other end which allows it to be turned as needed by the printer mechanism. The spools are wrapped in a supply of ribbon onto which the dye has been affixed. When in use, the end of this ribbon is attached to a take up real in a cartridge that is within the printer.

You suggest that the supply ribbon spools would be correctly classified the same as the ID card printer in 8443.32.1050 Harmonized Tariff Schedule of the United States (HTSUS). This is not correct as the spool is merely a part of the printer. Parts and accessories for printers are provided for elsewhere in heading 8443.

The applicable subheading for the thermal transfer supply ribbon spool will be 8443.99.2550, HTSUS, which provides for printing machinery…: parts and accessories: other: other: other. The general rate of duty will be free. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Mark Palasek at 646-733-3013.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division