NY 866780: The tariff classification of a disassembled Card Expressmachine from Canada

Native CBP ruling rendition. Applicability is fact-specific; modification/revocation relationships and original publisher date are retained. Publisher sentinel year0001 means unknown date, not a historical legal adoption.

                                   NY 866780

                               October 7, 1991


CLA-2-84:S:N:N1:103 866780  

CATEGORY:  Classification

TARIFF NO.: 8476.19.0000  

Mr. Michael M. Young
Pronto Printer
550 Cooper Center West
7150 N. Park Drive
Pennsauken, NJ 08109-4212

RE:  The tariff classification of a disassembled Card Express
machine from Canada

Dear Mr. Young:

     In your letter dated August 26, 1991 you requested a tariff
classification ruling.  

     The Card Express is a vending machine which prints small
quantities of business cards, invitations, announcements, or
similar articles.  It is a free-standing machine essentially
comprised of a vandal-proof cabinet incorporating a touch screen,
computer, film feeder and printer assembly, paper feeder, paper
cutter, and a unit which accepts money.  Upon depositing the
required amount of money an instruction program will be displayed
on the screen.  The program offers a choice of 4 card sizes, 26
layouts, and 5 typefaces.  The customer selects the desired card
size, layout, and typeface, as well as the desired wording, by
touching the appropriate spot on the screen.  After the
selections have been made, a thermal transfer printer prints 50
business cards or 25 double-sized invitations in about a minute. 
The Card Express machine is intended for installation at
conference and exhibition centers, airports, print shops, and
similar locations.  It measures 54 inches high, 24 inches wide,
and 24 inches deep, and has the capacity to supply up to 154
customers before resupply is required.

     You state in your inquiry that, except for the film feeding
and printing assembly, the entire Card Express machine is
composed of components of Canadian or U.S. origin.  The film
feeding and printing assembly is made in Japan, shipped to a U.S.
distributor, and then transshipped to Canada for assembly into a
Card Express machine.  After testing, the complete machine is
disassembled and shipped back to the U.S. where your firm re-
assembles it and ships it to its final location.  You state all
of the disassembled components, including the film feeder and
printer assembly, will be shipped in one crate.  

     The General Rules of Interpretation set forth the manner in
which merchandise is to be classified under the Harmonized Tariff
Schedule of the United States (HTS).  General Rule of
Interpretation 2(a) states, among other things, that any
reference in a heading to an article shall be taken to include a
reference to that article complete or finished, entered
unassembled or disassembled.  Accordingly, the applicable
subheading for the complete but disassembled Card Express
machine, imported in a single crate, will be 8476.19.0000, HTS,
which provides for other automatic goods vending machines.  The
duty rate will be 3.9 percent ad valorem.      

     Goods classifiable under subheading 8476.19.0000, HTS, may
be entitled to a free rate of duty under the United States-
Canada Free Trade Agreement (FTA) upon compliance with all
applicable regulations even though they contain components which
are not of Canadian or U.S. origin.  A copy of the applicable
regulations is attached for your information.

     This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).

     A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported.  If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
transaction.

                       Sincerely,

                                   
  
                         Jean F. Maguire
                         Area Director
                         New York Seaport