CLA-2-30:OT:RR:NC:N3:138
Lisa Tringali
Ormco Corporation
200 S. Kraemer Blvd. Brea, CA 92821
RE: The tariff classification of dental cements in retail packings from the United States
Dear Ms. Tringali:
In your letter dated June 30, 2023, you requested a tariff classification ruling.
Blugloo™, Grengloo™ and Enlight, imported in refill syringes, are used to affix dental brackets to the patient’s teeth. In your letter, you state the success of a fixed orthodontic appliance depends on the metal brackets being bonded to the teeth so that they do not fall off (debond) and protection against caries (decay) during treatment. Ortho Solo™ dental cement is a sealant and bond enhancer to be used with Blugloo™, Grengloo™ and Enlight. You also state these products are made in the United States and exported to Mexico for retail packaging and then imported back into the Unites States. In your letter, you state these products are used as dental cement and described as follows:
The first product, Blugloo™ (part number 740-0272), is a two-way color change bonding material that provides color contrast, making bracket placement and removal quick and easy. As Blugloo™ warms to the patient’s body temperature it turns clear and will remain that way. When the time comes for debonding the practitioner cools Blugloo™ with water or a blast of cool air and it turns blue making cleanup easy and thorough.
The second product, Grengloo™ (part number 740-0321) is a two-way color change bonding material that provides color contrast, strength, and flexibility. As Grengloo™ warms to body temperature the color disappears, remaining clear throughout the treatment. Once cooled with air or water, the color returns for debonding.
The third product, Enlight (part number 740-0195) is a flowable low-viscosity paste designed for lingual retainers and indirect bonding.
The last product, Ortho Solo™ (part number 740-0271) is a universal sealant and bond enhancer/primer for use with light-cure and chemical-cure bonding systems. Ortho Solo™ is designed to improve adhesion to the tooth at the bonding interface. It also acts as a stress and shock absorber, helping prevent cracks that can lead to bond failures.
The applicable subheading for the various dental cements in retail packings will be 3006.40.0000 Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Dental cements and other dental fillings; bone reconstruction cements.” The rate of duty will be free.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/current.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Judy Lee at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division