USMCA rules of origin and certificates

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Under USMCA, a good from Mexico enters the US free of duty only if it is 'originating' and the importer claims the preference at entry. This guide explains the origin tests, what a certification of origin must say, and what a valid claim saves as of October 23, 2026.

Published October 23, 2026 · Facts as of October 23, 2026 · 11 min read · Sources listed at the end · Rules as of October 23, 2026

Facts as of October 23, 2026. This page states the facts as they stood on that date. Tariffs, rules and figures may have changed since publication. Tariffs and trade policy change often, so we review these pages every month and update them.

88%Share of US imports from Mexico that were USMCA-compliant, January to May 2026 9
9Minimum data elements in a USMCA certification of origin. There is no required form 3
4 yearsHow long customs must accept a certification after it is completed 4
5 yearsMinimum time importers, exporters and producers keep origin records 4

What is it?

USMCA, called T-MEC in Mexico, gives duty-free treatment to goods that are 'originating' in Mexico, the US or Canada. A good qualifies if it is wholly made in the region, made only from originating materials, or meets the product-specific rule for its tariff line 2. The importer claims the preference with a certification of origin 3.

Why does it matter?

Mexico reported US$545.4 billion of exports to the US in 2025 1. As of October 23, 2026, a valid USMCA claim keeps a good out of the 10% Section 301 tariff that began on July 24, 2026 7,8. A failed claim adds that duty to the normal US rate.

How does it work?

The producer, exporter or importer completes a certification with nine data elements. The importer of record uses it to claim USMCA treatment at entry. All three keep records for at least five years, and US customs can verify the claim after the goods have entered 3,4.

01How does a good qualify as originating?

USMCA Chapter 4 sets the tests. A good is originating if it is wholly obtained or produced in the region. It is also originating if it is made in the region only from originating materials, or if it meets the product-specific rule for its tariff line in Annex 4-B 2.

Goods made with imported inputs use the product-specific rule. The usual test is a change in tariff classification, called a tariff shift: imported inputs must fall under a different tariff heading from the finished good. Some rules add a minimum regional value content (RVC) 2.

RVC is a percentage. Under the transaction value method, RVC equals the transaction value of the good minus the value of non-originating materials, divided by the transaction value, times 100. The net cost method uses the net cost in place of transaction value 2. Thresholds differ by tariff line: Annex 4-B sets 40% (transaction value) or 30% (net cost) for some chemicals, and 60% or 50% for some pharmaceuticals and cosmetics 2.

Two more rules matter. Under the de minimis rule, a good still qualifies if the non-originating materials that fail the tariff shift are no more than 10% of its value, with exceptions listed in Annex 4-A 2. Vehicles and core auto parts follow stricter rules, covered in our auto parts brief 5.

Compare

The ways a good can qualify under USMCA

Source: USMCA Chapter 4 2. Auto rules: USMCA Chapter 4 Appendix 5.
TestWhat it requiresExample
Wholly obtainedGrown, mined, raised or made entirely in Mexico, the US or Canada (Art. 4.2(a)) 2A crop grown in Mexico
Originating materials onlyMade in the region only from materials that are themselves originating 2A good assembled only from regional inputs
Tariff shiftImported inputs change tariff classification as set in Annex 4-B 2A good made with imported inputs
Regional value contentA minimum RVC by transaction value or net cost, alone or with a tariff shift (Art. 4.5) 2Chemicals (40% or 30%), some pharmaceuticals and cosmetics (60% or 50%)
De minimisNon-originating inputs that fail the shift are no more than 10% of value, with Annex 4-A exceptions (Art. 4.12) 2A good with a small foreign input
Auto rules75% RVC for vehicles and core parts; 70% North American steel and aluminum; 40% labor value content (45% light trucks) at US$16 an hour or more 5Passenger vehicles, light trucks, core parts

02What must a certification of origin contain?

USMCA sets no required form. The certification of origin can appear on a commercial invoice or any other document, as long as it carries the nine minimum data elements of Annex 5-A 3. The producer, the exporter or the importer may complete it 3.

One certification can cover a single shipment or identical goods shipped over a period of up to 12 months, called a blanket period 4. Customs must accept it for four years from the date it was completed 4.

The person who signs should hold the facts behind the claim: the tariff classification, the rule used, and the cost or sourcing data that proves it. The trade documents checklist covers the other papers in a shipment.

Checklist

The nine data elements of a USMCA certification

  • Certification typeWhether the importer, the exporter or the producer is certifying 3.
  • CertifierThe person or company that completes the certification 3.
  • ExporterThe exporter of the good 3.
  • ProducerThe producer of the good 3.
  • ImporterThe importer of the good 3.
  • Description and HS classificationA description of the good and its tariff classification at six digits 3.
  • Origin criteriaThe test the good meets, such as wholly obtained or the product-specific rule 3.
  • Blanket periodFor repeat shipments of identical goods, the period covered, up to 12 months 3,4.
  • Authorized signature and dateSigned and dated by the certifier, with the certification statement 3.
Element names follow the CBP USMCA FAQ, which lists the Annex 5-A minimum data elements 3. The certification can sit on an invoice or any other document.

03How does a claim travel from the plant to US customs?

The certification follows the goods. On the Mexican side, the customs declaration, the pedimento, records the USMCA preference. Our guide to customs brokers and the pedimento explains that filing. On the US side, the importer of record makes the claim when it files the entry 3,8.

Timing matters. The 10% Section 301 exemption applies to goods entered with a USMCA claim. Goods entered without a claim pay the duty 8. If the importer did not claim at entry, USMCA allows a refund claim within one year of importation, unless national law sets a longer period 4.

  1. Check the ruleThe producer classifies the good and checks the product-specific rule for its tariff line.
  2. CertifyThe producer, exporter or importer completes a certification with the nine data elements.
  3. Mexican exportA customs broker files the pedimento, which records the USMCA preference.
  4. US entryThe importer of record claims USMCA treatment when it files the entry.
  5. Keep recordsAll parties keep the evidence for at least five years in case of a verification.
The importer of record claims USMCA treatment at entry. From January to May 2026, 88% of US imports from Mexico were USMCA-compliant.

04Which rules and tariffs depend on the claim?

As of October 23, 2026, a valid claim does three things on the US side. It gives the normal duty-free USMCA rate. It exempts the good from the 10% Section 301 tariff on Mexican goods 7,8. For vehicles, auto parts and some industrial machinery, it lowers or removes the Section 232 duty 10,11.

Goods that fail origin pay the normal US duty rate plus the 10% Section 301 tariff, unless they fall under Section 232, which sets its own rate 8,11. The 25% tariff that applied to non-USMCA Mexican goods under the International Emergency Economic Powers Act (IEEPA) ended on February 24, 2026, after a Supreme Court ruling 14.

Our guide to US tariffs on Mexican goods shows how to work out the duty case by case. The live list of measures is on the corridor watch page.

On the Mexican side, higher duties that Mexico set on listed tariff lines from 2026 do not apply to originating goods that carry valid proof of origin and the identifier TL on the pedimento 12.

Rules in force
As of October 23, 2026. Live list: corridor watch.
MeasureWhat it doesSinceStatus
USMCA rules of origin (Chapter 4)Product-specific rules in Annex 4-B; 10% de minimis 2Jul 1, 2020In force
USMCA certification of origin (Chapter 5)No required form; nine data elements; valid four years; records five years 3,4Jul 1, 2020In force
US Section 301, forced labor10% on Mexican goods. Exempt with a USMCA claim at entry; goods under Section 232 excluded 7,8Jul 24, 2026In force
US Section 232, autos and parts25% (Proclamation 10908). USMCA-qualifying vehicles pay on non-US content; USMCA-qualifying parts exempt until Commerce sets a process 10Apr 3, 2025In force
US Section 232, Annex I-C machinery15% (Proclamation 11032). USMCA-qualifying goods from Mexico pay 25% on non-US content only, with a total of at least 15% 11Jun 8, 2026In force
Mexico duties on listed tariff linesHigher Mexican duties do not apply to originating goods with valid proof of origin and the identifier TL 12Jan 1, 2026In force
USMCA joint reviewUS did not agree to extend. Annual reviews; ends Jul 1, 2036 unless extended 6Jul 1, 2026Review open

05What records and audits follow a claim?

A claim can be checked years after the goods are sold. Importers must keep origin records for at least five years from importation. Exporters and producers keep them for five years from the date they completed the certification 4.

USMCA Article 5.9 allows a verification by written request, questionnaire or site visit. The company has at least 30 days to respond. Customs then has 120 days after it receives all the information to decide, extendable by up to 90 days in exceptional cases 4. If a claim is denied, the importer owes the duty that applies to a non-originating good.

Compare

Time limits in a USMCA origin claim

Source: USMCA Chapter 5, Articles 5.3, 5.8, 5.9 and 5.11 4.
StepTime limitWho it binds
Blanket periodIdentical goods over up to 12 months on one certification 4Certifier
ValidityAccepted for four years from completion 4Customs
RecordsAt least five years 4Importer, exporter, producer
Verification responseAt least 30 days to answer a request 4Exporter or producer
Decision120 days after all information is received, plus up to 90 days in exceptional cases 4Customs
Refund claimWithin one year of importation, unless national law allows longer 4Importer

06Where does origin affect cash?

Origin work costs money before the goods are paid for. Suppliers gather classification, cost and sourcing data, and meeting a rule can mean buying regional inputs. If a claim fails, the importer pays the duty in cash at entry, or later after a verification. Who carries that cost depends on the sale contract and its Incoterms rule.

Most corridor trade runs on open account terms, so the seller waits for payment while it carries these costs. Our guide to IMMEX covers the program that lets a company import inputs temporarily, without paying import duty, to make goods for export, and the tier supplier finance guide covers finance for auto suppliers.

Where the cash goes

From origin check to a settled claim

  1. Before production
    Origin dataThe supplier gathers classification, cost and sourcing data to support the claim.
  2. Production
    Materials and wagesMeeting a rule can mean buying regional inputs, which changes cost and supplier terms.
  3. Entry
    Duty or no dutyWith a valid claim, no US duty. Without one, the importer pays the normal rate plus any Section 301 or Section 232 duty.
  4. Invoice
    Waiting for paymentThe buyer pays on its terms, often after delivery on open account.
  5. Up to five years
    Verification riskA denied claim brings a duty bill for past entries. Records protect the claim 4.
The order of cash needs is typical for a supplier selling USMCA-qualifying goods. Actual days depend on each contract.
Before shipmentPre-shipment finance

Funds materials and production against a confirmed order.

After invoice, large buyerPayables finance

The buyer approves the invoice and a finance provider pays the supplier early.

New or unknown buyerLetters of credit

A bank undertakes to pay when the seller presents the agreed documents, which can include the certification of origin.

Buyer may not payTrade credit insurance

Covers most of an unpaid invoice if a covered buyer fails to pay.

07What should traders watch next?

USMCA stays fully in force. At the first joint review on July 1, 2026, the US did not agree to extend it. Annual joint reviews now follow, and the agreement would end on July 1, 2036 unless the three countries confirm an extension, which they may do at any time 6. US requests on auto content have been reported but are not in force 13.

  • No dateFourth round of US-Mexico talks. No date announced as of October 18, 2026 13.
  • ReportedUS requests for auto content near 82% regional value content and 50% US content. Not in force 10,13.
  • Jan 12, 2027Deadline for public comments to the US Trade Representative on the USMCA review 13.
  • Dec 31, 2027Temporary Section 232 metals rates under Proclamation 11032, including the Annex I-C treatment of USMCA goods, run to this date 11.
  • Jul 1, 2036USMCA ends on this date unless the three countries confirm an extension 6.

Questions traders ask

Is there an official USMCA certificate of origin form?

No form is required. The certification can be on an invoice or any other document, as long as it includes the nine minimum data elements listed in USMCA Annex 5-A. The US customs agency, CBP, lists them in its USMCA FAQ.

Who can issue a USMCA certification of origin?

The producer, the exporter or the importer can complete it. The person who signs should hold the classification, sourcing and cost data that prove the good qualifies.

How long is a USMCA certification valid?

Customs must accept it for four years from the date it was completed. One certification can cover a single shipment or identical goods shipped over a period of up to 12 months.

What happens if a Mexican good does not qualify under USMCA?

As of October 23, 2026, it pays the normal US duty rate plus the 10% Section 301 tariff on Mexican goods. If its tariff line is under Section 232, it pays the Section 232 rate instead of the Section 301 tariff.

How long must origin records be kept?

At least five years. Importers count from the date of importation. Exporters and producers count from the date they completed the certification.

Certifying USMCA origin for goods traded between Mexico and the US? Ossiano Capital works on trade finance in this corridor.

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Sources and notes

  1. UN Comtrade, annual trade data 2020 to 2025, all goods, Mexico and the US as reporters. Downloaded October 2026; 2025 figures may be revised. https://comtradeplus.un.org/
  2. Global Affairs Canada, CUSMA text, Chapter 4: Rules of Origin (consolidated text, informational). https://www.international.gc.ca/trade-commerce/trade-agreements-accords-commerciaux/agr-acc/cusma-aceum/text-texte/04.aspx?lang=eng
  3. US Customs and Border Protection, USMCA frequently asked questions. https://www.cbp.gov/trade/priority-issues/trade-agreements/free-trade-agreements/USMCA/FAQs
  4. Global Affairs Canada, CUSMA text, Chapter 5: Origin Procedures (consolidated text, informational). https://www.international.gc.ca/trade-commerce/trade-agreements-accords-commerciaux/agr-acc/cusma-aceum/text-texte/05.aspx?lang=eng
  5. Office of the US Trade Representative, USMCA text, Chapter 4 Appendix: Provisions related to the product-specific rules of origin for automotive goods. https://ustr.gov/sites/default/files/files/agreements/FTA/USMCA/Text/04_Rules_of_Origin.pdf
  6. White & Case, USMCA 2026 joint review: United States declines to extend agreement, July 2, 2026. https://www.whitecase.com/insight-alert/usmca-2026-joint-review-united-states-declines-extend-agreement-triggering-annual
  7. EY Tax News, USTR finalizes Section 301 forced labor tariffs on 60 economies, July 2026. https://taxnews.ey.com/news/2026-1607-ustr-finalizes-section-301-forced-labor-tariffs-on-60-economies-additional-tariffs-of-10-percent-or-125-percent-take-effect-24-july-2026
  8. Joffroy, Section 301 10 percent duty and USMCA entry, July 2026. https://joffroy.com/blog/section-301-10-percent-duty-usmca-entry
  9. Congressional Research Service, U.S.-Mexico Trade Relations (IF11175), August 13, 2026. https://www.everycrsreport.com/files/2026-08-13_IF11175_366b72c3fd2f3ebe10b28bf3feddca0088251bbb.html
  10. Baker Donelson, Automotive trade risks escalate as USMCA review, Section 232 tariffs and AD/CVD actions converge, July 15, 2026. https://www.bakerdonelson.com/automotive-trade-risks-escalate-as-usmca-review-section-232-tariffs-and-adcvd-actions-converge
  11. STR Trade Report, Section 232 tariffs on steel, aluminum and copper revised again, June 2026. https://www.strtrade.com/trade-news-resources/str-trade-report/trade-report/june/section-232-tariffs-on-steel-aluminum-and-copper-revised-again
  12. EY Mexico, Tax Flash: new import duties, December 31, 2025. https://www.ey.com/content/dam/ey-unified-site/ey-com/es-mx/technical/tax/documents/ey-tax-flash-nuevos-aranceles-importacion.pdf
  13. ICPA, USMCA joint review automotive tracker, October 18, 2026. https://www.icpainc.org/usmca-joint-review-automotive/
  14. Perkins Coie, Supreme Court holds IEEPA tariffs unlawful, February 2026. https://perkinscoie.com/insights/update/supreme-court-holds-ieepa-tariffs-unlawful-president-trump-terminates-and-partially

All facts on this page are as of October 23, 2026, the date of publication, and may have changed since. Rules and tariffs are as of October 23, 2026 and change often: check the corridor watch before you act.

About this guide. Prepared for Ossiano Capital. People planned, researched, wrote and checked this guide, using AI tools to help with research and checking. You are welcome to quote or reuse it: please credit Ossiano Capital and link to this page.

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