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NY M87456




November 2, 2006

CLA-2-30:RR:NC:SP:237 M87456

CATEGORY: MARKING

Mr. David R. Hamill
Arent Fox Attorneys at Law
1050 Connecticut Avenue, NW
Washington, DC 20036-5339

RE: Country of origin marking of dental points from China and South Korea.

Dear Mr. Hamill:

In your letter dated October 26, 2006, on behalf of Pentron Clinical Technologies LLC, you requested a country of origin marking ruling for dental points formed and shaped in China and South Korea from polyester resin originating in the United States.

Pentron manufactures dental points for filling root canals. The dental points are made from Resilon, a soft resin consisting of polymers of polyester containing fillers, radio pacifiers and bioactive glasses. Resilon resin produced in the United States is exported in pellet, sheet or rope form to facilities in China and South Korea for cutting, rolling and/or shaping to final form. The finished dental points are then imported by Pentron and sold in the United States to distributors or dentists.

Based on the information provided, the Resilon resin undergoes a substantial transformation from a semi-manufactured resin to formed and shaped dental points. Therefore, the country of origin for marking purposes is China or South Korea. In accordance with 19 CFR 134, Made in China or Made in South Korea must be marked on the plastic containers that are sold to dentists.

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 Frank Cantone at (646) 733-3038.

Sincerely,

Robert B. Swierupski

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