QUESTION: We are trying to determine how we should refer to certain products for the certification indicator under USMCA. We are a producer/manufacturer of plastic products, we also subcontract a few products. For the subcontracted products we own the molds, dictate materials used, produce some pieces and supply some pieces to our subcontractors for them […]
QUESTION: Our organization manufactures wiring harnesses for aircraft, appropriately classified in 8544.30. We are in the process of reviewing the USMCA. Can you please offer confirmation of my below interpretation: Rules of Origin USMCA 8544.11-8544.6047 A change to subheading 8544.11 through 8544.60 from any subheading outside that group, except from heading 74.08, 74.13, 76.05 or […]
QUESTION: My company does not currently employ FTA software and must rely on a mostly manual system of data collection, analysis and certificate creation. That aside, the extremely aggressive July 1 in-force date seems next to impossible to meet given the requirement of obtaining supplier certs prior to completing analysis, etc…even with an FTA software […]
QUESTION: I would like to inquire with the ICPA members if effective July 1, 2020 under the new USMCA FTA, importers will be responsible for any quota tariffs. For example, under HTS 1901207000, that quota rate is 42.3¢/kg + 8.5% but under NAFTA, the duty was deferred. I have received conflicting information regarding the USMCA […]
QUESTION: Regarding the NAFTA cutoff date, CBP states that “for merchandise entered into commerce on or before June 30, 2020, NAFTA rules will continue to apply.” Exactly what does that mean? At what point does a shipment enter into commerce? For an exporter, does that mean once it has been picked up? Do Incoterms tie […]
QUESTION: Can the membership please clarify how, and when to apply the 10% De Minimis in the USMCA, specifically, I think I am reading the language incorrectly. Can we use De Minimis if we are using an RVC rule? What about an intermediate good that is a part of a final assembly? The intermediate good […]
QUESTION: We are considering moving away from the usual calendar year (Jan – Dec) blanket certification date range to a Jul 1, 2020 – June 30, 2021 range. One reason is to move the annual supplier solicitation to mid-year, instead of year-end, which works better for my company. I’m interested to know what everyone’s plans […]
QUESTION: Is anyone aware of an existing or has anyone created one they would like to share? ========== Answers: Considering the minimum data element rules, it’s fairly straightforward until you get to the representation of origin of each particular good. It seems the government will release a suggested template like it has for AUSFTA, but […]
QUESTION: Does anyone in the trade community has a comparison chart of what changes from NAFTA to USMCA on the aspect of Textiles and Apparel? =========== Answer: There are a number of articles on this, including: https://www.just-style.com/analysis/new-nafta-20-the-devil-is-in-the-detail_id134687.aspx and USMCA – FAS.org Primarily, however, I think that we see a greater emphasis on using yarn […]
QUESTION: I have a couple of questions: NAFTA’s have been issued for the blanket period of January 1, 2020 through December 31, 2020. With the implementation of USMCA starting July 1, 2020, do all new documents for the current products, need to be issued using the USMCA wording to our customers and be requested from […]
QUESTION: Does USMCA also contain Preference Override like NAFTA does? ========== Answers: No. ========== This is a very good question. First, unlike NAFTA, the new USMCA agreement does not have a legal provision for the Marking of goods. Section 102.11 of the Customs regulations provides ostensibly for special marking rules under NAFTA. Because of this, […]
QUESTION: We are working through creating our new form and solicitation/data collection for USMCA. One data point that has me a little turned around is criterion D. Under NAFTA criterion D was clear for D1 and D2 (see below) and defined in CF434. They restructured the D subparagraph under USMCA rules of origin. And it […]
