Dental Trade Alliance (DTA) shares details on the new prohibition on transmitting sensitive personal data, including personal health data, to China enforcement to commence on July 8, 2025

On April 11, 2025, the National Security Division (NSD) of the Department of Justice (DOJ) published guidance and an FAQ on how it will enforce its January 8, 2025, final rule implementing Executive Order 14117 of February 28, 2024 (Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern). This final rule, called the Data Security Program (DSP), prohibits or restricts certain types of data transactions with six specific countries and certain people or entities within those countries. While the DSP and its interpretative guidance documents cover many different types of transactions, this memo only addresses the impact the DSP has on the scenario most likely triggered for certain DTA members—the transmission of biometric identifiers or personal health information related to U.S. citizens to dental laboratories or manufacturers based in China.

More information from DTA regarding this alert can be found at

FULL ALERT FROM DTA

If you have any questions about this alert or the topic, please contact Rick Van Arnam, DTA’s regulatory affairs counsel, at [email protected].

For over twenty years, the National Association of Dental Laboratories has had a public policy platform for transparency through enacting minimum standards for registration, education, and disclosure for dental laboratories within state law.

 On May 28^th, 2025, Oregon’s Governor Kotek signed into law, House Bill 2594. The passage of the bill was the result of a multi-year effort initiated by the Oregon Association of Dental Laboratories (OADL). The Washington State Dental Laboratory Association (WSDLA) also provided subject matter support to OADL during the process. The NADL as part of its strategic plan provided financial and legislative support for the Oregon advocacy initiative.

A link to the new law is provided below:
https://olis.oregonlegislature.gov/liz/2025R1/Measures/Overview/HB2594

The new law requires dental laboratories operating in Oregon to register with the Health Licensing Office (HLO), specifies requirements for obtaining registration, and requires dental laboratories to provide material content disclosures related to work orders completed for dentists in Oregon.

The registration requirement applies to dental laboratories that are located in Oregon and to facilities that are located outside of Oregon but do business with Oregon dentists.

As part of dental laboratory registration, the registered dental laboratory must employ either a dentist, a certified dental laboratory technician, or a dental technician who has completed acceptable continuing education.  There is a five-year grace period to meet the CDT requirement.

The law requires a dental laboratory registered with HLO to provide material content disclosures for any work orders received from a dentist.

Oregon’s new registration and disclosure requirements take effect on July 1, 2026.

The National Association of Dental Laboratories (NADL), alongside the Dental Trade Alliance (DTA) and the American Dental Association (ADA), has signed a joint letter urging President Trump to exclude medical devices and other essential supplies used by the American dental industry from any additional duties. The letter also requests the rollback of existing duties currently being assessed on medical devices critical to U.S. dental professionals. Click here to view the joint letter.

NADL’s mission is to create a vibrant dental laboratory profession through increasing industry awareness, building community and delivering critical resources.During the first Trump Administration, tariff proposals impacting dentistry, specifically dental laboratory products, were on the table for implementation.

Sources : https://www.bloomberg.com/news/articles/2017-04-21/your-imported-teeth-are-a-battlefield-as-trump-takes-on-trade?embedded-checkout=true; https://dentallabnetwork.com/forums/threads/nadl-response-to-bloomberg-article-on-dental-laboratory-imports.25947/