Question: As we approach the time of year to solicit our vendors for their USMCA certs, many won’t supply until way into January or February. Is there a grace period for USMCA filing? In other words, if I have a cert through 12/31, and haven’t received new year cert, can I legally claim until I […]
Question: Has anyone investigated the tariff shift rules across various free trade agreements for 8517.71 or 8517.79, specifically the discrepancy between the text of the International Trade Administration FTA text of the agreements and the text of the Harmonized Tariff Schedule of the United States Revision 25 (2025) General Notes? What I found is that […]
Question: FTA experts please help. I have a product that’s classified as 9401.99. It is a cushion for a vehicle seat. When I look at the rules of origin for the Colombia-US agreement, I don’t see any rules for 9401.99. Does this mean that there are no tariff shifts allowed for this HTS? So no […]
Question: Can the USMCA be applied to entries that qualify for 232 metal steel, aluminum, and copper tariffs? I was the impression that the only exclusion that applies is the 9903.0133. Am I correct? Answer 1: Sadly no. There is no USMCA exclusion for Section 232. Products subject to Section 232 are exempt from reciprocal […]
Question: How many companies issue a Certificate of origin or Free Trade Agreement per transaction (per shipment)? We have some customers requesting us to provide COO or FTA certificates on a per shipment basis. I prefer issuing a blanket statement that covers all the goods they purchase. Is there really a need to send a […]
Question: Should packaging materials be considered when doing RVC calculations for various FTAs? Do specific FTAs (USMCA, etc.) have specific rules regarding this? Answer 1: As a general rule, we do not include packaging with our RVC calculations. Answer 2: Article 4.15: Packaging Materials and Containers for Retail Sale 1. Each Party shall provide that […]
Question: Should packaging materials be considered when doing RVC calculations for various FTAs? Do specific FTAs (USMCA, etc.) have specific rules regarding this? Answer 1: As a general rule, we do not include packaging with our RVC calculations.
Question: Hi, The company I work for has an OEM manufacturer in Mexico. For product A, the CoO could be MX under USMCA while would be China under substantial transformation rule. However, when we talked to the team with the OEM manufacturer, they refused to change the CoO to MX. They said, even if they […]
Question: We are an infrequent importer and have not had an import from an FTA country to see how the 10% baseline ad valorem tax affects our imports. Do any (or all) of the FTA agreements provide an exemption against the 10% baseline to zero? Answer 1: I was just researching this today; specifically because […]
Question: I am told that only EU materials with a valid LTSD conferring preferential origin can be treated as EU originating in the preferential origin assessments of finished products made in the EU and incorporate these materials. Is this accurate? Where can I find official definition of originating materials? We can take the EU – […]
Question: Being a Trade Nerd, last night I couldn’t get a good night’s sleep because a question kept popping up in my head that I couldn’t answer. The question is: Any trade agreement that Pres. Trump negotiates must be approved by 2/3 of the Senate (67 Senators)) and there are only 53 Republican Senators (and […]
Question: My questions are related to the certificate of origin and the preference criteria for apparel imports into Canada under LDC. The B255 form is currently required for LDC clearance but the version available online is out of date – it reflects the rules of origin up to December 31, 2024. I’ve reviewed the updated regulations in SOR-2023-210 […]
