In the basal and/or suprabasal cell layers of human and rat gingiva, specialized epithelial cells (Merkel cells) were rarely observed with the electron microscope. They were less electron-opaque than keratinocytes and had a decreased number of desmosomes and tonofilaments. Small osmiophilic secretory-like granules were eccentrically located in the cytoplasm of the Merkel cells on the side apposing intraepithelial neurites. However, the specialization of gingival Merkel cells as receptors did not appear to be as high as the epidermal Merkel cells.