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Dental Laboratory Program - Annual Exemptions

Exemption Overview

A dental laboratory may be exempt from obtaining authorization from the Health Licensing Office (HLO) if it meets all three of the following requirements.

  • The laboratory is located in a dental office; and
  • The laboratory is owned and operated by, and under the supervision of, a practicing dentist; and
  • The laboratory does not perform work based on work orders that originate from outside of the dentist's practice.
If a dental laboratory meets all of these requirements, it does not have to obtain authorization from HLO; however, it must submit an annual exemption filing form to HLO. For more information about the exemption requirements and the annual filing process, please see the information below. The required exemption filing form will be available beginning September 30, 2026.

Annual Exemption Filing Required

Although an exempt dental laboratory does not need to obtain authorization, it must file information with HLO annually.

The annual filing is valid for one year and expires on the last day of the month one year from the date of issuance.

Note: A dental laboratory is exempt from authorization only if it continues to meet all of the exemption requirements described above. In particular, the laboratory must be located within a dental office, be owned and operated by and under the supervision of a practicing dentist, and perform work only for the dentist's practice rather than accepting work orders from outside practices.

What You Need to Know

Dental Laboratory Program Implementation Update 

House Bill 2594 (2025) created the Dental Laboratory Program within the Health Licensing Office (HLO). The bill establishes an operational date of July 1, 2026. 

The HLO is currently in the rulemaking process for implementation of the program. However, permanent administrative rules will not be in effect by July 1, 2026. As part of the rulemaking process, proposed fees are subject to review pursuant to ORS 291.055 by the Director of the Oregon Department of Administrative Services. 

Until permanent rules are filed and effective, the HLO is unable to begin accepting applications or collecting fees for Dental Laboratory authorizations. 

For this reason, the HLO will begin accepting applications and fees after permanent rules become effective. Additional information regarding application availability and program implementation timelines will be communicated as updates become available. 

Limited Waiver of Enforcement 

To support implementation of the new program, the HLO will exercise enforcement discretion during a limited transition period. 

From July 1, 2026, through October 31, 2026, the HLO will not impose discipline solely for operating a dental laboratory in Oregon without an HLO-issued authorization where authorization is required. 

This temporary waiver applies to:

  • Dental laboratories operating in Oregon that are required to obtain authorization under ORS 679.700 through 679.720; and
  • Exempt dental laboratories that are required to submit an annual filing with the HLO under ORS 679.705. 

This limited waiver applies only to authorization requirements associated with program implementation and does not waive compliance with any other applicable statutes or administrative rules. All other applicable statutory and regulatory requirements remain in effect and subject to HLO oversight and enforcement.

Annual Exemption Filing Form

Scope of Practice Questions

Do you have a question about how a law or rule impacts your individualized practice?
Please know that the Health Licensing Office (HLO) and its boards do not provide individualized advice on how the law applies to practice in the field. Here are some resources:
  • If you are looking for an attorney to provide you with legal advice about the statutes and rules governing your licensure, the Oregon State Bar has information on how to hire a lawyer.
  • If you wish to file a complaint against a person for potentially violating statutes or rules, you may review the complaint process.
  • If you wish to make a public comment on the statutes and rules governing your licensure, interested party feedback is encouraged at all public meetings.
  • If you believe HLO and the board's rules need to be amended, you may file a rule petition with HLO for consideration. Please note that any rules must fit within HLO and the board's current statutory authority. Please also know that the board will consider your position but might not adopt your proposed rule. The statute that governs rule petitions is ORS 183.390.
  • If you believe HLO and the board's statutes need to be amended, information about the legislative process is also available on the Oregon Legislature's website.
Please know the HLO and its boards remain neutral on substantive bills proposing changes to its laws and cannot act on your behalf in any proposals to change the governing statutes.

Questions?

For questions, please call (503) 378-8667, or go to the Health Licensing Office Contact Us page to search for staff that specialize in specific areas of expertise.