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 […]
QUESTION: I’m hoping I can receive some direction on the New Agreement with regards to imports into Mexico. For Mexico, there is duty avoidance when presenting NAFTA certificate on two charges: IGI Derecho de tramite Aduanero Will this still be the case for the new Agreement? ************* Answers: The current avoidance of the DTA (Derecho […]
QUESTION: I am interested in obtaining the opinions of the trade community regarding the use of a NAFTA cert as proof that a purchased item qualifies for the USMCA. All facts are the same between SPI “MX” and “S” for the items under review and the same fact pattern exists for the finished articles, meaning, […]
QUESTION: Per Annex 4-B of the new USMCA, Section (h) states the following: If the good is a vehicle of chapter 87 or a part listed in Tables A.1, B, C, D, E, F or G of the Appendix to this Annex for use in a vehicle of Chapter 87, the provisions of the Appendix […]
QUESTION: Are there any differences between Canada, US and Mexico on USMCA implementation guidelines? =========== Answer: All three counteis have yet to draft and agree on Uniform Regulations for USMCA. The Uniform Regulations are the rule book for how Customs in each of the three USMCA countries will administer the agreement. The implementation date hasn’t […]
QUESTION: Are there any differences between Canada, US and Mexico on USMCA implementation guidelines? =========== Addl Answer: CSMS #42429822 – US-Mexico-Canada Agreement (USMCA) Interim Implementation Instructions https://www.cbp.gov/trade/priority-issues/trade-agreements/free-trade-agreements/USMCA ========== Answer: All three counteis have yet to draft and agree on Uniform Regulations for USMCA. The Uniform Regulations are the rule book for how Customs in each […]
