CLA-2-84:RR:NC:1:110 C86924
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-50 Color Bubble Jet
Printer from Japan.
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-50 Color Bubble Jet (BJ) Printers when they are imported in the
same carton as the Color BJ ink cartridges which serve as their
printing mechanism. This BJC-50 Color BJ Printer is designed for
use as a computer output unit.
The printer is capable of printing in black and white or
color. Two different cartridges may be installed; the BC-11e
Color BJ Cartridge and the BC-10 Black BJ Cartridge. Only one
cartridge is installed at a time, and thus the user needs to
change cartridges depending on his printing needs.
The BC-11e Color BJ Cartridge incorporates a Bubble Jet
print head and four ink reservoirs containing black, cyan,
magenta, and yellow ink. The print head for the BC-11e 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-10 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, a replacement ink tank may be
installed.
The BC-11e and BC-10 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 is the
final image. Without a print head unit, no printing can be
performed.
Noting Legal Note 5(B) to Chapter 84 of the HTS, the BJC-50
Color Bubble Jet Printers would meet the definition of a "unit"
of an ADP system. Although the printer and the ink cartridges
(which contain the print head units), will be imported in the
same shipping cartons as the BJC-50 printers, they will be
detached from the printer assembly and enclosed in a sealed
plastic container. The BJ ink cartridges will thus not be
installed in the printers at the time of importation. Rather,
they will only be installed in the printers when they have been
purchased by retail customers in the Unites States. Bubble Jet
Printers shipped in the same carton as detached printing
mechanisms, and therefore not fully assembled units were the
subject of NY Ruling Letters C84386 and NY C80114.
The applicable subheading for the Canon BJC-50 Color Bubble
Jet Printer when the print head cartridges are not installed in
the printer but rather are separately packed in the same shipping
carton as detached printing mechanisms 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