The tariff classification of printer/contour cutter machines from Japan

NY I81926 June 17, 2002 CLA-2-84:RR:NC:1:103 I81926 CATEGORY: Classification TARIFF NO.: 8479.89.9600; 8477.80.0000 Mr. Joseph P. Cox Stein Shostak Shostak & O’Hara 515 South Figueroa Street, Suite 1200 Los Angeles, CA 90071-3329 RE: The tariff classification of printer/contour cutter machines from Japan Dear Mr. Cox: In your letter dated May 8, 2002 on behalf of Roland DGA Corporation you requested a tariff classification ruling. With your inquiry you submitted descriptive information on the ColorCAMM PC-12 desktop printer/cutter and the SOLJET SC-500 solvent printer/cutter. The PC-12 is a desktop machine which combines photo-realistic thermal printing with high precision contour cutting. It is used to produce short-run labels, decals, point-of-purchase displays, heat transfers, and similar graphics on vinyl or heat transfer materials up to 12 inches wide. The PC-12 can accommodate up to 9 ink cartridges simultaneously, allowing the operator to load both resin and wax inks at the same time. Utilizing the wax ink cartridges, the unit can print variable dot images at 2400 dots per inch. Alternatively, the resin ink cartridges allow printing at up to 600 dots per inch. Cutting of intricate text, arcs and curves is accurate to .3 percent or less of movement distance. A software RIP (raster image processor) allows designs to be output to the PC-12 from various standard computer design programs. The PC-12 is 22.375 inches wide, 17.25 inches deep, and 8 inches high, and weighs 22 pounds. The SOLJET SC-500 is a wide-format, 6 color inkjet printer and contour cutter used to produce outdoor signs that are UV and water resistant. It can print on and cut media, such as vinyl, canvas, banner and backlit film, up to 54 inches in width. It features a 64 nozzle piezo inkjet print head capable of printing resolutions up to 1440 dots per inch using solvent based inks, and a swivel drag cutting blade for high speed precision contour cutting. Like the PC-12, it works with a software RIP for computer design applications. Depending on the resolution desired, it can print at speeds ranging from 4 to 81 square feet per hour and can accommodate both roll and sheet media. With its stand the dimensions of the SC-500 are approximately 92 .5 inches by 29 inches by 50.6 inches, and it weighs 231.5 pounds. In your letter you stated the PC-12 is a smaller version of your client’s PC-60 thermal printer/cutter. The model PC-60 was the subject of two recent Customs Service rulings, file numbers HQ 965000 and HQ 965004, both dated March 28, 2002. In these rulings it was determined that the PC-60 performed two functions, thermal printing and contour cutting, which were described in headings 8479 and 8477, Harmonized Tariff Schedule of the United States (HTS), respectively. Both rulings went on to state that, as no principal function could be determined, the PC-60 was classifiable in heading 8479, HTS pursuant to General Rule of Interpretation 3(c). Likewise, the PC-12 thermal printer/cutter performs the functions of thermal printing and contour cutting, and a principal function cannot be determined. Thus, following GRI 3(c), it is also classifiable in heading 8479. The applicable subheading for the ColorCAMM PC-12 will be 8479.89.9600, HTS, which provides for machines and mechanical appliances having individual functions, not specified or included elsewhere (in chapter 84): other machines and mechanical appliances: other: other: printing machines other than those of heading 8443, 8471 or 8472 . The rate of duty will be free. You claimed in your letter that the SOLJET SC-500 inkjet printer/cutter should be classified in subheading 8479.89.9600, HTS, as well. However, unlike the PC-60 thermal printer/cutter described in Ruling Letters HQ 965000 and HQ 965004, the SC-500’s inkjet printing function is more specifically described in heading 8443. Heading 8443 provides for, inter alia, ink-jet printing machines, other than those of heading 8471 (the SC-500 is precluded from classification in heading 8471 by virtue of note 5(e) to chapter 84). The contour cutting function performed by the SC-500 remains described in heading 8477, which provides for machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere (in chapter 84). Since we are again unable to discern a principal function, following GRI 3(c) we find that the SOLJET SC-500 is classifiable in heading 8477, HTS. Specifically, the applicable subheading will be 8477.80.0000, HTS, which provides for machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere (in chapter 84): other machinery. The rate of duty will be 3.1 percent ad valorem. 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 Alan Horowitz at 646-733-3010. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division