The tariff classification of an "imaging module" for a digital photocopier from Japan.

NY B87634 July 23, 1997 CLA-2-84:RR:NC:1:110 B87634 CATEGORY: Classification TARIFF NO.: 9009.90.1000 Mr. John M. Peterson Neville, Peterson & Williams 80 Broad Street New York, N.Y. 10004 RE: The tariff classification of an "imaging module" for a digital photocopier from Japan. Dear Mr. Peterson: In your letter dated July 10, 1997, on behalf of Xerox Corporation, you requested a tariff classification ruling. The merchandise under consideration involves an input scanning "imaging module" for the Xerox A2-97 digital photocopier. The imaging module, as imported, will be housed in a metal frame measuring approximately 527 centimeters in length, 317 centimeters in width, and 94 centimeters in depth. It will include a raster output scanner (ROS), an illumination source (lamp), three mirrors, a lens, and a charge couple device (CCD). After importation into the U.S., a platen glass will be assembled on top of the imaging module. The imaging module will be mated with other modular building blocks, such as copy input modules, electronics control systems module, drive module, and a fuser module. The A2-97 digital copier operates in a slightly different manner from traditional "light lens" copiers. In the A2-97 copier, the original document to be copied is directed onto the platen, and exposed to light. The reflected image of the original is then transferred by mirrors through the lens and onto the CCD array. The electronic control module then manages the copying process from that point, by signaling the ROS within the imager, along with other aspects of the copying process. The image is then subjected to an electrostatic field, transferred to plain paper and fused in the customary manner. The sole distinction between the digital copier and the conventional "light lens" copier is that the image of the original document is not reflected onto the photoreceptor directly from a mirror, but is instead digitized, using the charge-couple devices and the ROS units, before being transmitted (by a laser), onto the photoreceptor. Noting the Explanatory Notes to the HTS and the definition of "optical" systems, the model A2-97 digital copier would thus appear to incorporate an optical system. The imaging module would also be covered under the provisions of the Additional U.S. Note 5 to Chapter 90 of the HTS. The applicable subheading for the imaging module will be 9009.90.1000 Harmonized Tariff Schedule of the United States (HTS), which provides for parts and accessories of photocopying apparatus of subheading 9009.12 specified in additional U.S. note 5 to this chapter, other than photoreceptors or assemblies containing photoreceptors. 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 Chief, Metals & Machinery Branch National Commodity Specialist Division