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NY 814221

September 25, 1995

CLA-2-90:R:N4:119 814221


TARIFF NO.: 9021.19.8500

Mr. Leonard M. Fertman
2049 Century Park East, Suite 1800
Los Angeles, CA 90067

RE: The tariff classification and status under the North American Free Trade Agreement (NAFTA) of Orthodontic Mesh Bonding Pads from Mexico; Article 509

Dear Mr. Fertman:

In your letter dated August 21, 1995, you requested a tariff classification ruling on behalf of Ormco Corporation, Glendora, CA.

The articles to be imported are orthodontic mesh bonding pads assembled in Mexico from components of U.S. origin. The completed articles vary in shapes and sizes but generally consist of a mesh bonding pad, a bracket for bonding, a .156" diameter brazed ring and a brazing foil. These components are exported to Mexico where they undergo a nine-step assembly process, including tack welding the mesh to the bracket, curving the bracket, welding mesh to bracket with brazing foil, furnace brazing and finish tumbling of the article.

The applicable subheading for the mesh bonding pads will be 9021.19.8500, Harmonized Tariff Schedule of the United States (HTS), which provides for artificial joints and other orthopedic or fracture appliances... other. The rate of duty will be 4.6 percent.

Since the components used to manufacture the product are of U.S. origin, the mesh bonding pads will have been made entirely in the territory of the United States and Mexico using only originating materials. The merchandise will have satisfied the requirements of HTSUSA General Note 12(b)(iii). It will therefore be entitled to a free rate of duty under the NAFTA upon compliance with all applicable laws, regulations and agreements.

This ruling is being issued under the provisions of Part 181 of the Customs Regulations (19 C.F.R. 181).

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.

This ruling letter is binding only as to the party to whom it is issued and may be relied on only by that party.


Roger J. Silvestri

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