Protocol Interface Controller and a second subassembly

HQ 085226 October 26, 1989 CLA-2 CO:R:C:G 085226 TLS CATEGORY: Classification TARIFF NO.: 8471.99.15; 8471.92.70 Richard M. Belanger, Esq. Powell, Goldstein, Frazer & Murphy Sixth Floor 1001 Pennsylvania Avenue, N.W. Washington, D.C. 20004 RE: Protocol Interface Controller and a second subassembly Dear Mr. Belanger: You request a ruling on the proper classification of two subassemblies under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA), that will be incorporated into the Pixelmaster color jet printer. Your letter dated July 25, 1989 has been submitted to this office for a reply. FACTS: The two components submitted for classification include a Protocol Interface Controller (PIC) and a unit that contains all of the other major elements of the printer. The PIC consists of a control board, a memory board, and an interface board, contained within a metal box with interface connectors to connect the printer to a computer system. The principal part of the PIC is the control board, which contains the main processor, a Motorola 68000, a custom VLSI data control chip, memory, a serial interface and a parallel interface, six eproms, and control logic and print engine interface electronics. The principal function of the PIC is to direct and regulate the operation of the printer by transmitting information from the computer to the print engine and instructing the print engines what to print and how to print it. The second subassembly contains all of the major elements that are not found in the controller. It includes a power supply, a print engine, a control panel, a print head assembly, a head tending subassembly, an ink feed subassembly, and a paper stacker subassembly. There is no dispute that this is a printer output unit that is classified under HTSUSA subheading 8471.92. ISSUE: Under which of the following subheadings of HTSUSA heading 8471 is the Protocol Interface Controller properly classifiable: 8471.99.60, HTSUSA, covering other units suitable for physical incorporation into automatic data processing machines or units thereof; 8471.99.15, HTSUSA, covering control or adapter units. Under which of the following subheadings of 8471 is the second subassembly properly classifiable: 8471.92.65, HTSUSA, covering assembled printer units incorporating at least the media transport, control, and print mechanisms; 8471.92.70, HTSUSA, covering printing units other than those of subheading 8471.92.65. LAW AND ANALYSIS: The General Rules of Interpretation (GRI) govern the classification of articles under the HTS. GRI 1 requires that classification be determined according to the terms of the headings and any relative section or chapter notes. The PIC is a unit that effects interconnection of the central processing unit (CPU) to other digital processing machines, or to groups of input or output units. In this case, the interconnection is between the CPU and second subassembly, which is an output unit. The Explanatory Notes (EN) offer additional guidance here. Under EN 84.71(I)(D)(4), control and adapter units are described as machines that effect interconnection of the central processing unit to other digital data processing machines, or to groups of input or output units. The PIC fits this description and as a result is properly classifiable under subheading 8471.99.15. The second subassembly is not a complete printer output unit as it is presented for classification. It does not have a controller board, which is usually a part of a complete printer unit. The controller board needed for this unit will be provided when the PIC is connected to it. Subheading 8471.92.65 specifically calls for "assembled units." This subassembly cannot be considered assembled because it lacks an essential component that would make it a complete unit. Therefore, it is properly classifiable under subheading 8471.92.70. HOLDING: The Protocol Interface Controller is classified under subheading 8471.99.15, HTSUSA, as a control unit. The second subassembly unit is classified under subheading 8471.92.70, HTSUSA, as a printer unit other than that which is assembled. Sincerely, John Durant, Director Commercial Rulings Division