QUESTION: Under USMCA, General Note 11(o) for Chapter 28 reads: 1. (A) A change to subheadings 2801.10 through 2853.00 from any other subheading, including another heading within that group; or (B) No change in tariff classification to a good of subheadings 2801.10 through 2853.00, provided there is a regional value content of not less than: […]
QUESTION: An item imported into the US is made in Asia and classified in Chapter 84. An upgrade kit is imported into the US is also from Asia, and is classified in Chapter 85. The upgrade results in an item classified in Chapter 92. Would this now qualify as originating for USMCA? I believe this would, […]
QUESTION: We are manufacturing a good in Canada with Chinese origin inputs and Canadian packaging and labor, then shipping to Mexico. The good does NOT undergo a substantial transformation and so the COO will remain China. Question: Is there any way to separate out the North American component so that our customer in MX can […]
QUESTION: Article 4.2 and Annex 5-A provide for the 9 elements necessary to be included on a valid USMCA cert. I do not see in either 4.2 or Annex 5-A a legal obligation to have “TS” “RVC”, etc… stated on the USMCA cert for it to be a valid cert. Can the membership please explain […]
QUESTION: My Mexican broker is refusing the USMCA certificate that lists the corporate address as the “exporter” address. He is insisting that I provide a different USMCA certificate for every plant location. We are a large company, and have multiple plants. The certificate includes goods for we are the producer, as well as goods which […]
QUESTION: We are currently in the process of completing USMCA certification and have come across a question on a part we supply to a customer for which we also pay VMI (vendor managed inventory) storage costs. We recover this cost in our selling price. For RVC calculation using the net cost method, would we have […]
QUESTION: Looking for the membership feedback on interpreting USMCA Automotive rules for passenger vehicle service/replacement parts. Background: Our company supplies original equipment service parts to a distributor in Canada. The parts and accessories provided for the passenger vehicles are used by dealers to replace OEM parts in the vehicles as needed. The parts that we […]
QUESTION: 1. I was wondering what would be the best response to give Suppliers who insist on providing USMCA certificates with countries of origins not in the program. Where does it state that this disqualifies the entire certificate? 2. How do we respond to requests to complete a USMCA that state: “Include Country of Origin […]
QUESTION: When filing out the certificate of Origin for USMCA is the requirement to only list items with Country of Origin – USA, ,MX or CA? What about items where country of origin is other than the three countries in the agreement? =========== Answer: The USMCA – United States, Mexico and Canada Agreement is only […]
QUESTION: What happens if there is no rule in the USMCA for your HTS? I have an item with an HTS of 8544.42 that is built into a finished product with an HTS of 8536.30, but it is not for a motor vehicle. The subheading rule for 8544.42 says nothing about non-motor vehicles; see below. […]
QUESTION: I’m being asked by one of our customers to provide a USMCA cert for a product that they have not sourced from us since 2018. Even if I were able to get our 2018 data to do an analysis, can I certify something made in 2018 for USMCA that went into effect in 2020? […]
QUESTION: We are a manufacture of an end products. Some of our products are purchased internationally. Many of our products are purchased domestically and are manufactured in the USA. Our problem is this. Our clients request a USMCA certificate for the products go to OEM’s who export to Canada and Mexico. Since most of our […]
