CLA-2-84:RR:NC:1:110 C87602
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 the Canon BJC-5000/BJC-500J
Color Bubble Jet Printers from Mexico.
Dear Mr. Grace:
In your letter dated May 4, 1998, on behalf of Canon
Business Machines, Inc., you requested a tariff classification
ruling.
The merchandise under consideration involves the Canon BJC-5000 Color Bubble Jet Printers when individual units are imported
in the same shipping cartons as BJ ink cartridges which serve as
their printing mechanism. This printer model is also known as
the Canon BJC-500J Color Bubble Jet Printer. The BJC-5000/BJC-500J Color Bubble Jet Printer is designed for use as a computer
output device.
The BJC-5000/BJC-500J Color Bubble Jet Printers are capable
of printing in black and white or color. However, before they
can function as printers, cartridges containing ink jet print
heads must be installed. The BJC-5000/BJC-500J is a "dual head"
machine with two separate cartridge slots. Any of three
different print head cartridges may be installed in either slot.
These print head cartridges are known as the BC-23 Enhanced Black
BJ Cartridge; the BC-21e Color BJ Cartridge, and/or the BC-22e
Photo BJ Cartridge.
The BJC-5000/BJC-500J optimizes the printing process based
upon the combination of cartridges installed in the machine. The
BC-23 Enhanced Black BJ Cartridge incorporates a bubble jet print
head and a black ink reservoir. Each print head contains 128
nozzles. When the ink runs out, the entire cartridge is
replaced.
The BC-21e Color BJ Cartridge incorporates a bubble jet
print head and two replaceable ink tanks (the BCI-21 Black Ink
Cartridge and the BCI-21 Tri-Color Ink Cartridge). The print
head for the BC-21e Color BJ cartridge contains 64 nozzles for
black ink and 72 nozzles for color (24 nozzles for each color).
The BC-22e Photo BJ Cartridge incorporates a bubble jet
print head and an ink reservoir. The print head contains 64
nozzles for black ink and 72 nozzles for color (24 nozzles for
each color). When the ink runs out, the entire cartridge is
replaced.
All of the cartridges utilize the same technology. 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 unit, no printing can be
performed.
Noting Legal Note 5(B) to Chapter 84 of the HTS, the BJC-5000/BJC-500J 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-5000/BJC-500J printers,
they will be detached from the printer assembly and enclosed in
sealed containers. 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 United 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 C86924 and NY C86219.
The applicable subheading for the Canon BJC-5000/BJC-500J
Color Bubble Jet Printers 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