The tariff classification of Minolta Digital Multifunction Machines from Japan.

NY G88225 March 29, 2001 CLA-2-84:RR:NC:1:110 G88225 CATEGORY: Classification TARIFF NO.: 8471.60.6300 Mr. R. Brian Burke Rode & Qualey 295 Madison Avenue New York, NY 10017 RE: The tariff classification of Minolta Digital Multifunction Machines from Japan. Dear Mr. Burke: In your letter dated March 8, 2001, on behalf of your client Minolta Corporation, you requested a tariff classification ruling. The merchandise under consideration is the Minolta DiALTA Color( CF2001 and CF1501. From the literature provided with your ruling request, the CF2001 and CF1501 are described as Digital Full-Color Copier/Printer/Scanners. These units are modular and offer many optional units and equipment. This allows the purchaser to configure the system to their particular needs. This ruling is limited to the principal components of the system, the main (printer) unit and the scanner unit. These units will be imported together but without their controller units, which enables an end-user to customize the machine to meet the needs of a particular automatic data processing system. With optional controllers, both units offer a full range of connectivity and networking capabilities. The CF2001 and CF1501 multifunction machines incorporate fine edge enhancement technology, which can achieve resolutions of 600 DPI x 1800 DPI. Both machines offer 600 DPI high resolution scanning and printing. The CF2001 can produce 20 full-color pages per minute, while the CF1501 can produce 15 pages per minute. Both machines contain a light emitting diode (LED) print engine. In this system, a digital file is created from the original document and stored in on-board memory. This digital image is then written onto a photosensitive surface not by a single laser and a rotating mirror, but rather, by a light bar assembly containing 600 LEDs per inch. There are four (4) separate photoconductor drums in the print engine, each with its own LED light bar assembly. Each drum, using a different color toner (yellow, magenta, cyan and black) transfers the image produced on the drum to the surface of an electrostatically charged transfer belt. This full-color image is then transferred from the surface of the belt to the surface of the paper. The Minolta CF2001 and CF1501 can create hard copy documents from any digital file, whether it is received into memory from the input scanning unit or from an automatic data processing system through a controller unit. The scanner is removable and comes with a 2.5-meter long cable that allows this unit to be placed away from the main (printer) unit, offering greater flexibility in configuration. Although not dispositive or legally binding, the Harmonized Commodity Description and Coding System Explanatory Notes, which constitute the official interpretation of the Harmonized Tariff Schedule (HTS) at the international level, may be utilized. The EN’s provide a commentary on the scope of each heading of the HTS, and is generally indicative of the proper interpretation of these headings. Since the scanner unit and main unit are not “designed to be permanently attached to each other or to a common base” they are not composite machines as noted in Section XVI, General (VI) of the Explanatory Notes (EN’s). However, the Minolta Models CF2001 and CF1501 are composite goods made up of different components as noted in GRI 3(b), that being the scanner unit and a main (printer) unit. Accordingly, they shall be classified as if consisting of the material or component, which gives them their essential character. The main (printer) unit appears to impart the essential character to these multifunction machines. The applicable subheading for the Minolta DiALTA Color( CF2001 and CF1501, when imported without their controller units will be 8471.60.6300, Harmonized Tariff Schedule of the United States (HTS), which provides for “Automatic data processing machines and units thereof…Input or output units…Other: Printer units: Other: Light bar electronic type.” 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 Eileen S. Kaplan at 212-637-7019. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division