USMCA Trade Agreement Advice

The United States-Mexico-Canada Agreement (USMCA) provides duty-free or reduced-duty treatment for goods that qualify under its Rules of Origin. However, determining whether a product qualifies isn’t always straightforward. This document outlines the key aspects of USMCA qualification, explains how to certify origin easily, and details what to expect if U.S. Customs requests additional verification.

What Qualifies for USMCA?

Many importers ask what products qualify under USMCA, but there is no simple inclusion/exclusion list based on Harmonized Tariff Schedule (HTS) codes or classifications. Instead, qualification is determined by the Rules of Origin outlined in the agreement.

Some goods, such as natural resources (e.g., minerals mined in Canada or crops grown in the U.S.), clearly qualify as originating. However, products that are manufactured, assembled, or contain mixed materials from multiple countries require more in-depth analysis to determine eligibility.

Note: Goods that were cleared between March 4 and March 6 are currently considered non-exempt from the tariffs that went into effect at 12:01 am ET on March 4, 2025. 

Understanding the USMCA Rules of Origin (Simplified)

To qualify under USMCA, a product must meet one of the following conditions:

1. Wholly Obtained or Produced – The product is entirely sourced or produced within the USMCA region (e.g., mined minerals, farmed crops, livestock born and raised in a USMCA country).
2. Produced Exclusively from Originating Materials – All components or ingredients used in the product are from the USMCA region.
3. Tariff Shift Rule – If a product includes non-USMCA materials, it must undergo a substantial transformation that results in a change to a different HTS classification.
4. Regional Value Content (RVC) Requirement – Certain products, such as automotive goods, must meet a percentage threshold of regional content based on either:
   
   • Transaction Value Method (based on the selling price)
   • Net Cost Method (based on production costs)
5. De Minimis Rule – Allows up to 10% of non-originating content in most products while still qualifying for USMCA treatment (different thresholds apply to textiles).

Certifying Origin – FREE on Zipments.io

We understand that determining USMCA qualification can be complex, so we offer a free tool on Zipments.io to help with certification. Our Origin Certifier allows you to:

✔️ Determine if your goods qualify under USMCA rules. ✔️ Generate a compliant Certification of Origin (no official form is required, but specific data elements must be included). ✔️ Store and retrieve certificates for future reference.

This service is free — Simply create your Zipments.io account to get started.

https://app.zipments.io/tools/origin-certification

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Broker Clearance & Potential CBP Requests

Once your goods arrive in the U.S., your customs broker will process the clearance using the USMCA certification. In most cases, this completes the process, and your goods will be released without additional duties.

However, U.S. Customs and Border Protection (CBP) may request additional verification in some cases. If this happens, CBP will issue a Customs Request for Information (CF 28), which will be sent directly to the Importer of Record (IOR) and CC your broker. This request does not mean your goods are disqualified—it simply means Customs is reviewing your claim.

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How to Respond to a CF 28 (Customs Request for Information)

If you receive a CF 28, CBP may ask for:

📌 Bill of Materials (BOM) – A breakdown of all product components and their origins. 📌 Supplier Certifications – Proof that raw materials or components qualify under USMCA. 📌 Production Process Details – Documentation on where and how the product was made. 📌 Shipping Records – Proof that the goods were shipped directly between USMCA countries. 📌 Regional Value Content (RVC) Calculation – If applicable, CBP may require cost breakdowns. 📌 Inventory & Accounting Records – If using an inventory management method (FIFO, LIFO, etc.), CBP may request supporting records. 📌 Prior Rulings or CBP Determinations – If applicable, any prior rulings or classifications should be provided. 📌 Manufacturing Facility Information – Location(s) of production facilities and proof that production took place in a USMCA country.

Failure to respond to a CF 28 can result in duties being assessed retroactively or further scrutiny on future shipments.

Stay Prepared – Keep Records for 5 Years

To avoid compliance issues, importers should maintain all supporting documentation for at least 5 years after claiming USMCA treatment. Working closely with your suppliers and customs broker ensures you’re prepared in case of an audit or verification request.

For assistance with USMCA compliance, visit Zipments.io or reach out to your broker.

How the A & A Group of Companies Can Help

Our team of experts is here to assist with your USMCA compliance needs. Whether you need help with HTS classification, origin certification, or brokerage services, we’ve got you covered.

📌 HTS Verification & Consulting – Unsure of your product’s correct classification? Our specialists can verify your HTS code and help ensure compliance.

📌 Origin Certification Assistance – Use our free Origin Certifier tool on Zipments.io to generate your USMCA certification, or contact us for consulting support.

📌 Need a Broker? 

✔️ Ship more than 10 shipments per month? Contact A & A Customs Brokers at 1-888-538-5658, sales@aacb.com, or https://www.aacb.com/contact-us

✔️ Ship less than 10 shipments per month? Contact BorderBuddy at 1-877-409-8163, service@borderbuddy.com, or https://borderbuddy.com/contact

The A & A Group of Companies

The A & A Group of Companies provides a full suite of customs brokerage, trade compliance, and technology-driven logistics solutions, supporting importers and exporters of all sizes across North America. Together, these companies offer a data-driven perspective on trade trends and help businesses navigate the complexities of international trade.

A & A Customs Brokers

A trusted name in customs brokerage since 1979, A & A specializes in large and enterprise-level import/export operations across the U.S. and Canada. With a strong focus on compliance, tariff classifications, and trade advisory services, A & A ensures seamless customs clearance for businesses managing complex cross-border supply chains.

BorderBuddy

Since 2007, BorderBuddy has been a digital-first customs brokerage, catering to SMBs, individual importers, and e-commerce shippers. By simplifying the import process with an easy-to-use online platform, BorderBuddy provides cost-effective and efficient customs clearance solutions for smaller businesses looking to scale.

Zipments.io

A leading trade technology platform, Zipments.io processes over 150,000 users per month and handles millions of PARS lookups annually. The platform offers real-time shipment tracking, customs release notifications, commercial invoice generation, HS classification, duty and tax calculation, and USMCA origin documentation.

Together, these companies provide customs expertise, regulatory compliance, and trade technology solutions for importers and exporters across all industries.

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Disclaimer

This document is intended for general informational purposes only and does not constitute legal, tax, or compliance advice. While we strive to provide accurate and up-to-date information, regulations and interpretations may change over time. For personalized guidance on USMCA compliance, tariff classification, or customs procedures, we recommend consulting with a qualified trade compliance expert or reaching out to our team for professional support.