# USMCA Rules of Origin Checklist for Manufacturers > Source: https://netray.co/tools/usmca-rules-of-origin-compliance-checklist > Publisher: Netray (netray.co), AI and integration engineering for ERP and manufacturing systems. > Section: Free Tools ## Short answer Step through classification, the product-specific rule, regional value content, certification and record keeping for USMCA claims. ## Category compliance-legal ## Region United States, Mexico, Canada ## Industry Manufacturing ## Audience - Trade compliance - Customs broker - Supply chain manager - Exporter ## Tool **Kind:** checklist **Groups:** #### Product and classification **Items:** **Text:** Finished good classified to a 6-digit HS subheading with documented rationale **Critical:** true Classification reviewed against the 8-digit tariff schedules of the importing country **Text:** Bill of materials available with part numbers, descriptions and unit costs **Critical:** true Each component classified to its own HS subheading Goods confirmed as not wholly obtained or produced, or wholly obtained status documented if they are Any special regimes (automotive, textiles, de minimis) identified for this product #### Applying the product-specific rule **Items:** **Text:** Product-specific rule located in the USMCA Annex 4-B for the HS heading of the finished good **Critical:** true **Text:** Rule type identified: tariff shift, regional value content, a combination or a specific process **Critical:** true For tariff shift rules, each non-originating input compared to the required shift **Text:** For regional value content rules, method chosen (transaction value, net cost) and applied consistently **Critical:** true Threshold checked against the rule, including any alternative rule Roll-up and tracing treatment documented for intermediate materials De minimis allowance considered only where the rule and goods permit it #### Supplier data **Items:** **Text:** Origin declarations obtained for each material or component claimed as originating **Critical:** true Supplier declarations signed, dated and covering the period of use Unknown-origin parts treated as non-originating in the calculation Suppliers asked to notify you of changes in sourcing or processes Costs for regional value content tied to ERP cost records, not estimates Currency and valuation basis stated for each cost used #### Certification of origin **Items:** **Text:** Certification prepared by the importer, exporter or producer with the minimum data elements required by the agreement **Critical:** true **Text:** Includes certifier, exporter, producer and importer details, description and HS code, origin criterion and blanket period if used **Critical:** true Signed and dated by the certifier with the required certification statement Certification valid for four years from signing, and blanket period not longer than twelve months Process in place to stop use if the facts change #### Records and verification readiness **Items:** **Text:** Records kept for at least five years after the date of the claim (or longer, by country) **Critical:** true **Text:** Calculation worksheets, BOMs, supplier declarations and cost records stored together by product **Critical:** true Named owner for responding to a verification request from customs Procedure for corrections and notification when an error is found Periodic review of top products when suppliers, costs or the rule change Training for purchasing and shipping staff on origin claims **Scoring Note:** Critical items are those a customs authority is most likely to test in a verification. This checklist is a planning aid. Product-specific rules are detailed and change, so confirm each claim with your customs broker or trade counsel. ## Content **Intro:** To claim USMCA preferential duty treatment, a good must be originating, and the importer needs a certification and the records to prove it. This checklist guides trade compliance teams through classification, the product-specific rule, supplier evidence and record keeping so a verification request does not become a scramble. **Sections:** #### How to use the checklist **Body:** Start with classification and the bill of materials, because every later step depends on them. Work through each group in order for one product at a time, ticking only what you can support with a document. Export the result for the product file. Repeat when a supplier, a material cost or the rule itself changes, and keep the completed checklist with your calculation worksheet. #### What decides originating status **Body:** A good can be originating if it is wholly obtained, produced entirely from originating materials, or meets the product-specific rule in the agreement's annex. Most manufactured goods qualify through a tariff shift, a regional value content test, or both. The rule you must use depends on the heading of the finished good. The agreement also contains separate rules and higher content thresholds for certain automotive products, and special rules for textiles, so identify those early. **Bullets:** - Wholly obtained or produced - Produced entirely from originating materials - Meets the product-specific rule in the annex - Special regimes for autos and textiles #### Evidence behind a certification **Body:** A certification of origin has minimum data elements but no mandatory form, and anyone claiming the preference needs to hold the supporting records. For manufacturers this usually means a BOM with costs, supplier origin declarations, the calculation and the signed certification. Keep them together per product. If a verification request arrives, the first question is whether you can produce the calculation and the supplier evidence without delay. #### Common mistakes and ERP notes **Body:** Frequent problems are using the wrong HS code, relying on supplier declarations that have expired, mixing valuation methods in the same calculation and failing to update the claim when a source changes. In your ERP, hold HS code and country of origin on the item and approved supplier records, store cost roll-ups by period and attach declarations to the vendor. A BOM-based regional value content rollup is much easier when those fields are clean. **Cta:** Netray can help connect your BOM, cost and supplier origin data from your ERP so that a regional value content calculation can be prepared for your trade team to review. **Faq:** #### Is there a required USMCA certification form? **Answer:** No specific form is mandated. The certification must include the minimum data elements listed in the agreement and be signed and dated. Many companies use a template that captures those elements. Use a template, or the importing country's guidance, as a starting point for your own. #### How long do I keep USMCA records? **Answer:** At least five years from the date of the claim under the agreement, and some countries require longer for certain records. Keep calculation worksheets, supplier declarations, cost records and the signed certification in one product file. #### Do unknown-origin parts count as originating? **Answer:** No. If you cannot document origin, treat the part as non-originating when applying a tariff shift or computing regional value content. Asking suppliers for signed declarations early gives you better evidence and often a stronger result. #### Who can certify origin? **Answer:** The importer, exporter or producer may complete the certification. Whoever signs is responsible for the accuracy, so they should hold or have access to the supporting records, not only the final form. ## Search terms usmca rules of origin checklist, usmca compliance checklist, usmca product specific rules, usmca regional value content, usmca tariff shift, usmca certification of origin requirements, usmca originating goods manufacturer, usmca record keeping five years --- Talk to an engineer: https://netray.co/contact?intent=erp_ai | Machine catalog: https://netray.co/agent/catalog.json