Classification of ink reservoir, a product of Japan, underthe Harmonized Tariff Schedules of the United States (HTSUS).

HQ 088227 Feb 6,1991 CLA-2 CO:R:C:G 088227 JGH CATEGORY: Classification TARIFF NO.: 3215.90.5000 Mr. Paul E. Dixon Customs Broker 149-21 177 Street Jamaica, New York 11434 RE: Classification of ink reservoir, a product of Japan, under the Harmonized Tariff Schedules of the United States (HTSUS). Dear Mr. Dixon: Your letter of September 28, 1990, to Customs at New York, concerning the tariff classification of an ink reservoir to be imported by Pilot Corporation of America, Inc., has been referred to this office for reply. A sample of the ink reservoir with ink and the un-inked plastic sponge were submitted. FACTS: The ink reservoir is a plastic sponge impregnated with ink, shaped to fit in a ribbon cartridge designed for a printer. A diagram of the ribbon cartridge showing the application of the ink reservoir was submitted. It provides what the promotional literature refers to as a "re-inking system" for the ribbon. ISSUE: Classification of the ink reservoir under the HTSUS. LAW AND ANALYSIS: Since the provision for printers, heading 8471, HTSUS, does not include parts of the cartridge, classification would not fall into this provision. Similarly, heading 9612,HTSUS, for ribbon cartridges, does not apply, since parts of cartridges are not included. -2- Accordingly, since the ink reservoir is a composite article, it would be classifiable according to General Rules of Interpretation ( GRIs) under GRI 3(b), HTSUS. Under this rule, classification would be according to the essential character of the article. Since the essential character of the reservoir is not the plastic sponge but the ink, the ink reservoir would be classifiable in heading 3215, HTSUS. HOLDING: Ink Reservoir for a ribbon cartridge is classifiable under the provision for other inks in subheading 3215.90.50, HTSUS. The rate of duty is 1.8 percent ad valorem. Sincerely, John Durant, Director Commercial Rulings Division 6cc A.D., N.Y. Seaport 2cc CIE hurley library/peh 088227