CLA-2-84:S:N:N1:110 804130
Mr. Christopher E. Pey
Barnes, Richardson & Colburn
475 Park Avenue South
New York, N.Y. 10016
RE: The tariff classification of a Color Card Printer from Japan
Dear Mr. Pey:
In your letter dated November 7, 1994, on behalf of Mitsui &
Co., you requested a tariff classification ruling.
The merchandise under consideration involves a card printer,
to be sold under the name "NTT Teleca Smart Color Card Printer".
This card printer prints information (including color photos) onto
plastic and PET cards. The cards printed by the machine are flat
and measure 3 3/8" x 2 1/8". The printer uses a thermal transfer
printing method with sublimation dye to print in color.
The printer has a built-in color scanner to permit standalone
operation without a personal computer but appears to be principally
used with personal computers. When used with personal computers,
storage and retrieval of information and database management can
also be accomplished. In this mode, the printer operates as both
an input and output device for a personal computer, which is used
to edit the picture scanned by the printer and incorporate data
stored on the PC onto the card printed by the machine. The printer
is used primarily to print employee identification cards, licenses,
certificates and greeting cards.
The printer scans by means of a CCD image sensor, has a
scanning area of 108mm x 58mm (max), and can print cards
continuously at 40 cards per hour. The printer weighs
approximately 38kg, and incorporates a precision built-in color
controller. Although capable of operating in a stand-alone mode,
the machine in its System 2 and 3 configuration (with personal
computer), appears to be the principal use of this printer.
Noting Legal Note 5 (B) to Chapter 84 of HTS, this printer would
meet the definition of a "unit" of an ADP system.
The applicable subheading for the Color Card Printer will be
8471.92.4600, Harmonized Tariff Schedule of the United States
(HTS), which provides for thermal transfer printers, assembled
units incorporating at least the media transport, control and print
mechanism. The duty rate will be 3.7 percent ad valorem.
Your inquiry does not provide enough information for us to
give a classification ruling on the Teleca Card Cleaner. Your
request for a classification ruling should include the complete
specifications for the cleaning and deburring mechanism. Please
provide a sample of a card that requires deburring. Would the lack
of this card cleaning have a direct impact on the function of the
printer, or are these independent operations?
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