Multifunction printer classification: computer-linked output units fell under Heading 8471.60, not the residuary office-machine heading.

Multifunction digital printer-copier-scanner-fax machines were treated as classifiable under Heading 8471.60 as output units of automatic data processing machines, not under Heading 8472.90 as other office machines. The majority reasoned that, on the catalogue and technical literature, the goods functioned as multifunction devices capable of standalone use and computer-linked operation, that Note 5(D) of Chapter 84 governed printers meeting the conditions in Notes 5(B)(b) and 5(B)(c), and that printing was their principal function. Heading 8472 was treated as residuary and could not displace the specific heading, with earlier Tribunal rulings on similar machines followed in judicial discipline. The result was classification under Heading 8471.60.

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Issues: Whether multifunction digital printer-copier-scanner-fax machines were classifiable under Heading 8471.60 as output units of automatic data processing machines or under Heading 8472.90 as other office machines.

Analysis: The machines were shown by the catalogue and technical literature to be multifunction devices capable of printing, copying, scanning and faxing, and capable of operating both in stand-alone mode and in conjunction with a computer. The majority held that Note 5(D) of Chapter 84 governed printers satisfying the conditions of Note 5(B)(b) and 5(B)(c), and that the goods answered that description. It was further held that the machines had printing as their principal function, that Heading 8472 was residuary in nature, and that the earlier Tribunal decisions classifying similar multifunction machines under Heading 8471.60 should be followed in judicial discipline. The competing reliance on Note 5(E) and residual classification under Heading 8472.90 was rejected.

Conclusion: The goods were classifiable under Heading 8471.60 and not under Heading 8472.90.

Dissenting Opinion: One Member held that the machines were principally designed to work with computers, that Heading 8472 was only residuary, and that the earlier Tribunal rulings supported classification under Heading 8471.60; accordingly, the appeal should have been allowed on that basis.

Final Conclusion: The majority held that the multifunction machines fell for classification as output units under Heading 8471.60, with the consequence that the assessee succeeded in the appeal.

Ratio Decidendi: A multifunction machine that satisfies the conditions for a printer under Chapter 84 and has printing as its principal function is classifiable under Heading 8471.60, and a residuary office-machine heading cannot be applied where the goods are covered by the specific heading.

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