NY 862408
Apr 19 1991

CLA-2-84:S:N:N1:110 862408

Ms. Madeline B. Kuflik
Matsushita Electric Corporation of America
One Panasonic Way
Secaucus, New Jersey 07094

RE: The tariff classification of laser beam printers without control units from Japan.

Dear Ms. Kuflik:

In your letter dated April 12, 1991, you requested a tariff classification ruling. The merchandise under consideration involves various models of industrial grade laser beam printers that are used in the high end of the desktop publishing field where high grade quality printed products are produced in-house.

The printers include the following models: FP-L140XG; FP- L140XU; FP-L140LD; FP-L140LDE; FP-L300EMU; FP-L300EMG; FP- L301EMU; FP-L301EMG; and FP-L800, all of which are imported and sold to OEM customers. The OEM customers add the controllers, or more commonly called control units to the imported printers. The function of the control unit is to convert the signal from the computer into a language which can be understood by the printer, and to define the format of the eventual printed page. Unlike the ordinary office laser printer, which normally incorporates the control mechanism, these industrial laser beam printers lack the control mechanism upon importation, and thus are not complete output units. These laser beam printers can print from 300 to 600 dots per inch (dpi), while office-type printers print at only 300 dpi.

The imported printers known in the trade as "engines" or "imagesetters" can have the control units either mounted on top of the printer, or in some cases mated as separate stand alone control units. Since these imported models lack the control unit, they are not complete output printers since they lack the ability to convert signals provided by the computer into an intelligible form.

The applicable subheading for the laser beam printers without control units will be 8471.92.7000, Harmonized Tariff Schedule of the United States (HTS), which provides for other printer units. The rate of duty will be free.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director
New York Seaport