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NY N014121





July 20, 2007

CLA-2:RR:NC:N1:113

Ms. Jeannette Messina
Ormco Corporation
305 South Acacia Street, Unit B
San Dimas, CA 91773

Dear Ms. Messina:

We are returning your request for a ruling, and any related samples, exhibits, etc. We need additional information in order to issue a tariff classification and country of origin marking ruling on the Orthodontic Temporary Anchorage System (TAS). You also ask for the country of origin and country of origin marking requirements for the DD springs and coil springs when imported and sold separately. Please submit the information described below:

The TAS Kit contains a sterilization cassette, driver and tips, TAS initiator, coil springs, DD springs, mini-screws and tissue punch. You state that the sterilization cassette, driver, TAS initiator and mini-screws are made in Germany. The tissue punch is made in Japan, and the DD springs are made in the United States. The items that comprise the TAS Kit are imported separately into the United States. The imported items are packaged with the other kit components in a plastic box for retail sale. You state in your letter that you are requesting a ruling on the complete TAS Kit, however, you are importing the kit components separately. You also indicate that you do not plan to import the complete TAS Kit. Please state the kit components for which you are requesting a ruling. Provide the item number or style number for each item.

Please limit your ruling request to a maximum of 5 items of the same class or kind.

You state in your letter that you included TAS photos, engineering drawings and Manufacturing Control Instructions (MCIs). However, we have not received this material. For the DD spring, please provide MCI-0623 and MCI-0625. For the swivel eyelet spring (also referred to as a vector coil spring with a swivel assembly), please provide MCI-0631.

You state that the DD spring and coil spring will be formed using nickel and titanium wire made in Belgium. Provide a breakdown of these component metals by weight.

Describe each process performed on the nickel and titanium wire in the United States to form the DD spring and coil spring. Will the springs be cast?

For the DD spring, Ormaco will purchase vector triangular eyelets of United States origin, tumble them and manually attach one to each end of the nickel and titanium spring. Provide a breakdown of these component metals by weight for the DD spring with the vector eyelets attached.

List the step by step processes performed in the United States to produce the tack welded assembly. Please describe the tack welding and tumbling processes.

Describe in detail each process performed on the tack welded assembly in Mexico.

If you decide to resubmit your request, please include all of the material that we have returned to you and mail your request to U.S. Customs and Border Protection, Customs Information Exchange, 10th Floor, One Penn Plaza, New York, NY 10119, attn: Binding Rulings Section.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 177).

If you have any questions regarding the above, contact National Import Specialist Ann Taub at 646-733-3018.

Sincerely,

Robert B. Swierupski, Director
National Commodity Specialist Division

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