HQ 087102: Classification Of "Kits" For Photocopiers And Laser Printers

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.

                            HQ 087102

                         August 8, 1990

CLA-2  CO:R:C:G  087102  CMS

CATEGORY: Classification

Mr. William R. Wilson
Manager, Customs Operations
Centralized Logistics Organization
Xerox Corporation
800 Phillips Rd., Bldg. 0205-99P
Webster, NY  14580

RE: Classification Of "Kits" For Photocopiers And Laser Printers

Dear Mr. Wilson,

     Your correspondence dated April 18, 1990, requesting a
classification ruling on certain "kits" for photocopiers and
printers has been referred by the Regional Commissioner of
Customs, New York to Customs Headquarters for a reply.

     The merchandise is described as "kits" used in the
installation, upgrade and repair of photocopiers and laser
printers.  No descriptions are provided for any of the articles
which make up the "kits".

     The Office Of Regulations And Rulings will cooperate in any
way possible to issue classification rulings on products which
are adequately described.  However, it is impossible for Customs
to determine whether articles are classified as parts,
accessories, sets or eo nomine goods when no specific article
descriptions are provided.  CR 177.2(b)(2)(ii)(A) provides that
"...the request for a ruling should include a full and complete
description of the article...".

     You state that it would be unfeasible to request rulings on
every kit because there are thousands of different kits.
Although we appreciate your problem, it would be inappropriate
for us to adopt your proposed solution inasmuch as there is no
basis for it either in law or in the Customs regulations.  One
possible approach would be for Xerox to request rulings on a
small number of kits representative of the merchandise you
import which, with discretion, could then be applied to similar
kits.

                               -2-

     Although no ruling can be issued in response to your April
18, 1990 request as submitted, the Office Of Regulations And
Rulings will of course issue a ruling when adequate descriptions
of the articles which make up the "kits" have been provided.



                                   Sincerely,





                                   John Durant, Director
                                   Commercial Rulings Division