CLA-2-84:RR:NC:1:110 C86920
Mr. David R. Grace
Covington & Burling
1201 Pennsylvania Avenue, N.W.
P.O. Box 7566
Washington, D.C. 20044-7566
RE: The tariff classification of a Canon BJC-4400 Color Bubble
Jet Printer from Japan and Thailand.
Dear Mr. Grace:
In your letter dated April 16, 1998, on behalf of Canon
Computer Systems, Inc., you requested a tariff classification
ruling.
The merchandise under consideration involves the Canon BJC-4400 Color Bubble Jet (BJ) Printers when they are imported in the
same shipping carton as the Color BJ ink cartridges which serve
as their printing mechanism. This BJC-4400 Color BJ Printer is
designed for use as a computer output unit.
The printer is capable of printing in black and white or
color. Three different cartridges may be installed; the BC-21e
Color BJ Cartridge, the BC-20 Black BJ Cartridge, and the BC-22e
Photo BJ Cartridge. Only one cartridge is installed at any time,
and thus the user needs to change cartridges depending on his
printing needs.
The BC-21e Color BJ Cartridge incorporates a Bubble Jet
print head and two ink tanks. The BCI-21 Color ink tank contains
reservoirs for cyan, yellow, and magenta ink. The BCI-21 Black
ink tank contains a reservoir for black ink only. The print head
for the BC-21e Color BJ cartridge contains a total of 136
nozzles; 64 nozzles for black and 24 nozzles for each of the
three colors. When the ink runs out, replacement ink tanks may
be installed.
The BC-20 Black BJ Cartridge incorporates a Bubble Jet print
head and a black ink reservoir. The print head contains 128
nozzles. When the ink runs out, the cartridge must be replaced.
The BC-22e Photo BJ Cartridge incorporates a Bubble Jet
print head and four reservoirs, containing cyan, yellow, magenta,
and black ink. The print head contains a total of 136 nozzles;
64 nozzles for black and 24 nozzles for each of the three colors.
When the ink runs out, the cartridge must be replaced.
The three cartridges are designed for use in Canon's BJC
printers and have no other uses. Each nozzle on the print head
units contains a heater. When the heater is turned on, ink is
vaporized forming an air bubble. As the bubble expands, ink is
expelled out of the open end of the chamber. Upon striking the
print media, the expelled ink forms a contrasting dot. The
selective printing of dots results in the final image. Without a
print head, no printing can be performed.
Instead of packing a single printer assembly and Color BJ
cartridge in a shipping carton, the foreign supplier will pack
three partially assembled printers, three Color BJ cartridges
(and associated ink tanks), three dedicated AC adapters, and
three printer cartridge storage boxes in a single shipping
carton. Although the printers and Color BJ cartridges will be
shipped in the same carton, the cartridges will be detached from
the printer assemblies and enclosed in separate sealed
containers.
Following importation, the contents of a shipping carton
would typically be repacked into three retail display boxes. A
single printer assembly, Color BJ cartridge, dedicated AC
adapter, and printer cartridge box would be placed in each retail
display box. The Color BJ cartridges will not be installed in
the printer until after the unit has been purchased by a retail
customer in the United States.
Noting that the Canon BJC-4400 Color Bubble Jet Printer and
the Color BJ cartridges are packed separately from the ink jet
printers, the printers should be treated as "unassembled units"
even though the shipping cartons in question will contain three
partially assembled printers, three Color BJ cartridges (and
associated ink tanks), three dedicated AC adapters, and three
printer cartridge storage boxes. Bubble jet printers shipped in
the same shipping carton as detached printing mechanisms, and
thus not fully assembled units were the subject of NY Ruling
Letters C84386 and NY C80114.
The applicable subheading for the Canon BJC-4400 Color
Bubble Jet Printer shipped as three partially assembled ink jet
printers, three sealed Color BJ cartridges (and associated ink
tanks), three dedicated AC adapters, and three printer cartridge
storage boxes, which are separated packed in a single shipping
carton, will be 8471.60.6400, Harmonized Tariff Schedule of the
United States (HTS), which provides for other ink jet printers.
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 Art
Brodbeck at 212-466-5490.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division