QUESTION: CBP does not allow products made with non-originating materials in an FTZ to qualify for USMCA into the US even if it meets the ROO. “Under NAFTA rules of origin, non-originating goods used in production processes in foreign trade zones (FTZ) could not qualify as originating as a result of that processing. See 19 […]
QUESTION: The Implementation Act now prohibited that FTZ manufactured products can qualify for USMCA preferential tariff. As a producer, can we take advantage of the accumulation provision for a component or material that was manufactured in a FTZ. ************* Add’l Answer: This is what the implementation act as amended now states: ‘‘(3) SPECIAL RULE FOR […]
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: Under the minimum data requirements for USMCA certification I don’t see that “Method of Qualification” is required. We have customers who ask us to provide the method of qualification as shown below. Our current template doesn’t have this field, so do I need to provide it? *******************You are correct. Under the NAFTA C/O you […]
QUESTION: I’m hoping for insight from the membership regarding USMCA, specifically rule of origin #77 for chapter 90: “A change to a good of 9031.90 from any other good within that subheading or any other subheading.” The seems to be a convoluted way of saying that a tariff shift is not necessarily required. Am I […]
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 […]
