Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada.
GST/HST Rulings Directorate
5th floor, Tower A, Place de Ville
320 Queen Street
Ottawa ON K1A 0L5
[Client Address]
Case Number: 170680
Business Number: […]
June 13, 2025
Dear [Client]:
Subject: GST/HST ruling
Application of the GST/HST to healing abutments, healing caps, and closure screws
that are part of a dental implant system.
Thank you for your correspondence of [mm/dd/yyyy], concerning the application of the goods and services tax/harmonized sales tax (GST/HST) to healing abutments, healing caps, and closure screws that are part of a dental implant system. We apologize for the delay in this response.
The HST applies in the participating provinces at the following rates: 13% in Ontario; 14% in Nova Scotia; and 15% in New Brunswick, Newfoundland and Labrador and Prince Edward Island. The GST applies in the rest of Canada at the rate of 5%.
All legislative references are to the Excise Tax Act (ETA) unless otherwise specified.
STATEMENT OF FACTS
From your correspondence and […][the Company] website, [...][website address], we understand the following:
1. The Company specializes in implant, restorative and regenerative dentistry. It conducts research, develops and manufactures dental implants, instruments, prosthetics, tissue and bone regeneration biomaterials for use in both tooth replacement and restoration, or to prevent tooth loss.
2. […][parent company] has offices worldwide. All questions pertaining to this letter are in relation to supplies of goods and services made in Canada by the Company.
3. The Company is a GST/HST registrant under registration number […].
4. The Company supplies dental goods and services to dental professionals in Canada.
5. Among the Company’s broad range of implant dentistry products are the following dental products: implants, healing abutments, healing caps, and closure screws.
6. An implant is a small part made of titanium or titanium zirconium that is placed in the jaw bone in lieu of a missing natural tooth’s root.
7. The Company’s healing abutments, healing caps and closure screws (the products) are components of a dental implant system used following an implant surgery.
8. These products are temporary in nature given that they are used during the healing phase post-dental implant surgery and then replaced by other similar final components once healing has occurred.
9. These products can generally be in a patient’s mouth for two to eight months prior to the final placement of a crown.
10. A general brief description of the products and their usage is as follows:
a) Healing abutment: is a connector piece that is placed on top of an implant fixture and protrudes into the oral cavity connecting the implant with the artificial tooth (or prosthesis). A healing abutment is designed to shape and maintain the soft tissue architecture. It serves as a temporary replacement for the natural tooth during the healing process.
b) Healing cap: is a component used as a gum former to cover, stabilize, and protect the inner configuration of an implant. After being placed onto the implant, the gum tissue is then brought around the healing cap and held in place with dissolvable sutures where an impression is made into the gum for when the final abutment is placed.
c) Closure screw: a component, also known as a healing or cover screw, that is a screw-like device used in dental implant procedures to cover and seal the implant fixture during the healing period. A closure screw can be at bone-level or at tissue-level depending on the implant used. It is designed to protect the implant fixture and provide stability.
RULING REQUESTED
You would like to know if supplies of healing abutments, healing caps and closure screws used within a dental implant system are zero-rated pursuant to section 26 of the Part II of Schedule VI.
RULING GIVEN
Based on the facts set out above, we rule that the supplies of healing abutments, healing caps, and closure screws are zero-rated pursuant to section 32 of Part II of Schedule VI.
EXPLANATION
Generally all supplies of goods and services made in Canada are subject to the GST/HST unless specifically relieved under the ETA. There are exceptions for medical devices that are specifically identified in Part II of Schedule VI as being zero-rated; i.e., the tax applies at the rate of 0%. If a medical device is not included in Part II of Schedule VI, then the supply of the medical device would be subject to tax at the rate of 5%, 13%, 14% or 15% as applicable, unless another zero-rating or exempting provision were to apply.
General Information – Part II of Schedule VI
Part II of Schedule VI lists medical devices for human use that are zero-rated (taxable at 0%) under the ETA. Some devices are zero-rated in their own right (e.g. supplies of artificial eyes, artificial teeth, hearing aids) while other devices are zero-rated only when supplied under certain conditions (e.g. on the written order of a specified professional for use by a consumer named in the order, or specially designed for use by an individual with a disability).
Section 1.1 of Part II of Schedule VI provides that for purposes of Part II of Schedule VI, other than section 33, a supply of property (e.g., a medical or assistive device), that is not designed for human use or for assisting an individual with a disability or impairment is deemed not to be included in this Part.
In addition, section 1.2 of Part II of Schedule VI provides that a cosmetic service supply and a supply, in respect of a cosmetic service supply, that is not made for medical or reconstructive purposes are deemed not to be included in Part II of Schedule VI (i.e., not zero-rated).
If a medical or assistive device is not included in Part II of Schedule VI, then the supply of that device would be subject to tax at the applicable rate, depending on the province in which the supply is made, unless another provision in the ETA applies to zero-rate or exempt the supply.
Section 25 of Part II of Schedule VI
Section 25 of Part II of Schedule VI zero-rates a supply of a medical or surgical prosthesis, or an ileostomy, colostomy or urinary appliance or similar article that is designed to be worn by an individual. The CRA considers a medical or surgical prosthesis to be a device that permanently replaces a missing part of the body, corrects a physical deformity or malfunction, or supports a weak or deformed part of the body. This artificial device could be an externally worn device or an implanted device that is worn internally. Where the device is not to be permanently implanted into the recipient, it would not qualify as a surgical prosthesis.
A dental implant is permanently implanted to be worn internally by an individual. It provides support to the jawbone by protecting from bone atrophy and it permanently replaces the root of a missing tooth. Therefore, a dental implant is zero-rated pursuant to section 25 of Part II of Schedule VI.
Section 32 - Part, accessory or attachment that is specially designed
Section 32 of Part II of Schedule VI zero-rates a supply of a part, accessory or attachment that is specially designed for a medical and assistive device listed in Part II of Schedule VI (e.g. artificial teeth).
Of note, section 32 of Part II of Schedule VI is not read in isolation. That is, this section is subject to the conditions set out in sections 1.1 and 1.2 of Part II of Schedule VI. Section 1.1 of Part II of Schedule VI generally provides that a supply of any medical or assistive device listed in that Part that is not designed for human use or for assisting an individual with a disability or impairment is deemed not to be included in Part II of Schedule VI. Section 1.2 of Part II of Schedule VI provides that a “cosmetic service supply”1 (as defined in section 1 of Part II of Schedule V) and a supply, in respect of a cosmetic service supply, that is not made for medical or reconstructive purposes are deemed not to be included in Part II of Schedule VI.
Healing abutments, healing caps and closure screws attach to the dental implant post and serve as a shield for the gums to help prevent infections and other issues. The products protect the dental implant, that is serving as a root, from contamination at the time of healing. The products also secure the space for a crown (the artificial tooth) that is yet to be placed after the healing of the implant surgery. Hence, the products are affixed to the dental implant as attachments in order to enhance the functionality of the implant itself. So, with regards to qualifying under section 32 of Part II of Schedule VI, the products in question are considered to be attachments of a property described in section 25 of Part II of Schedule VI.
A determination as to whether these products are specially designed for a device, such as a dental implant, is made based on an evaluation of the overall features of these products. The specially designed features must be significant and make the products recognizably different from other goods without the specially designed features. Therefore, in determining if the particular products have been specially designed for use as parts, accessories or attachments to a zero-rated medical or assistive device (e.g., to a dental implant), it is important to consider how the initial manufacturer intended the product to be used, as shown by its design features, qualities and capabilities. In other words, to determine if a part, accessory or attachment is specially designed, there must be evidence of a direct connection between the design features of the part, accessory or attachment and the manufacturer's intent to design (deliberately incorporate specific design features into) the product for a property described in Part II of Schedule VI.
The CRA will determine whether a part, accessory or attachment is specially designed based on the initial manufacturer's ultimate use of the part, accessory, or attachment. The part, accessory or attachment must be specially designed for a particular medical device and generally does not have an alternative use. The fact that a product can be used with a medical device does not mean that the product is a specially designed part, accessory or attachment for a medical device listed in Part II of Schedule VI. The qualifier “specially” imposes a restriction on the word “designed” which excludes general-purpose products from the zero-rating provision.
Healing abutments, healing caps and closure screws come in a variety of shapes, forms and sizes that best fit the type of implant being used. They are also fabricated with different material types and techniques and designed depending on their positioning in a patient’s mouth and on their clinical application within an implant to suit the implant type (tissue-level, bone-level, or mini-implant), the implant diameter size (2.4mm, 3.3mm, 4.1mm, 4.8mm, etc.), and the implant material (titanium, ceramic, zirconia, resin composite, or polymer material). Therefore, the healing abutments, healing caps and closure screws that are used as part of a dental implant system are designed and manufactured in such a way to correspond to the surgical choice of the implant that is inserted within the jawbone, hence making them specially designed attachments to a dental implant.
Conclusion
Based on the facts stated above, the healing abutments, healing caps and closure screws are designed for human use or for assisting an individual with an impairment as per section 1.1 of Part II of Schedule VI. Furthermore, they are not a cosmetic service supply or a supply in respect of a cosmetic service supply as per section 1.2 of Part II of Schedule VI. The healing abutments, healing caps and closure screws are specially designed attachments for a dental implant appliance which is zero-rated pursuant to section 25 of Part II of Schedule VI. Therefore, the supplies of healing abutments, healing caps and closure screws, as parts of an implant system, are zero-rated pursuant to section 32 of Part II of Schedule VI.
DISCLAIMER
In accordance with the qualifications and guidelines set out in GST/HST Memorandum 1-4, Excise and GST/HST Rulings and Interpretations Service, the Canada Revenue Agency (CRA) is bound by the ruling(s) given in this letter provided that: none of the issues discussed in the ruling(s) are currently under audit, objection, or appeal; no future changes to the ETA, regulations or the CRA’s interpretative policy affect its validity; and all relevant facts and transactions have been fully and accurately disclosed. The interpretation(s) given in this letter, including any additional information, is not a ruling and does not bind the CRA with respect to a particular situation. Future changes to the ETA, regulations, or the CRA’s interpretative policy could affect the interpretation(s) or the additional information provided herein.
CONTACT
If you require clarification with respect to any of the issues discussed in this letter, please call me directly at 343-553-4626.
Should you have additional questions on the interpretation and application of the GST/HST, please contact a GST/HST Rulings officer at 1-800-959-8287.
Sincerely,
Amal Khorchid
Senior Rulings Officer
Health Care Sectors Unit
Public Service Bodies and Governments Division
GST/HST Rulings Directorate
1 cosmetic service supply means a supply of property or a service that is made for cosmetic purposes and not for medical or reconstructive purposes
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