USMCA Rules of Origin Checklist for Manufacturers

0%

0 of 30 items complete

10 critical items still open - these are the highest-risk gaps.

Download checklist:

Product and classification

Finished good classified to a 6-digit HS subheading with documented rationaleCRITICALClassification reviewed against the 8-digit tariff schedules of the importing countryBill of materials available with part numbers, descriptions and unit costsCRITICALEach component classified to its own HS subheadingGoods confirmed as not wholly obtained or produced, or wholly obtained status documented if they areAny special regimes (automotive, textiles, de minimis) identified for this product

Applying the product-specific rule

Product-specific rule located in the USMCA Annex 4-B for the HS heading of the finished goodCRITICALRule type identified: tariff shift, regional value content, a combination or a specific processCRITICALFor tariff shift rules, each non-originating input compared to the required shiftFor regional value content rules, method chosen (transaction value, net cost) and applied consistentlyCRITICALThreshold checked against the rule, including any alternative ruleRoll-up and tracing treatment documented for intermediate materialsDe minimis allowance considered only where the rule and goods permit it

Supplier data

Origin declarations obtained for each material or component claimed as originatingCRITICALSupplier declarations signed, dated and covering the period of useUnknown-origin parts treated as non-originating in the calculationSuppliers asked to notify you of changes in sourcing or processesCosts for regional value content tied to ERP cost records, not estimatesCurrency and valuation basis stated for each cost used

Certification of origin

Certification prepared by the importer, exporter or producer with the minimum data elements required by the agreementCRITICALIncludes certifier, exporter, producer and importer details, description and HS code, origin criterion and blanket period if usedCRITICALSigned and dated by the certifier with the required certification statementCertification valid for four years from signing, and blanket period not longer than twelve monthsProcess in place to stop use if the facts change

Records and verification readiness

Records kept for at least five years after the date of the claim (or longer, by country)CRITICALCalculation worksheets, BOMs, supplier declarations and cost records stored together by productCRITICALNamed owner for responding to a verification request from customsProcedure for corrections and notification when an error is foundPeriodic review of top products when suppliers, costs or the rule changeTraining for purchasing and shipping staff on origin claims

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.

USMCA product files from your ERP

Optional: see how BOM, cost and supplier data can be assembled into a per-product origin file.

Optional. The tool and every export work without this. No spam.

How to use the checklist

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

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.

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

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

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.

Frequently Asked Questions

Is there a required USMCA certification form?

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?

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?

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?

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.

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.

Talk to an Expert Explore More Free Tools

Related Tools

Compliance & Contracts

More Compliance & Contracts tools

See all