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Dear Friends and Customers,

Please be sure to review and update to the most updated USMCA Final Implementing Instructions which replace the USMCA Interim Implementing Instructions issued on June 16, 2020. These instructions provide guidance on the new requirements under the USMCA, including information on USMCA entry, compliance, rules-of-origin, origin certifications, new auto requirements, textile requirements, and other requirements for claiming USMCA preferential treatment for goods.

The supporting USMCA regulations, the new Part 182 of Title 19, Code of Federal Regulations (19 CFR 182) that includes the USMCA Uniform Regulations,  have been issued today July 1, 2020.  Additionally, the Harmonized Tariff Schedule of the United States will be amended effective, July 1, 2020 to include General Note 11 (GN11) with information on the USMCA rules of origin, product specific rules, and other requirements.

Effective July 1, 2020, the North American Free Trade Agreement (NAFTA) terminates and the USMCA enters into force.

The USMCA Implementing Instructions – June 30, 2020  CBP Publication Number 1118-0620.
There will be a Phase I Implementation, the first six months upon entry into force (July 1, 2020 to December 31, 2020), in which CBP understands that the trade may need time to adjust business practices to comply with the new requirements under the USMCA, particularly relating to the preferential tariff treatment of goods.
During the first six months after entry into force, CBP will focus on supporting the trade’s efforts to fully comply with USMCA requirements, including providing webinars and other outreach efforts to educate the trade on the new Agreement.

Importers are required to exercise reasonable care when making a claim under USMCA, including ensuring that they are in possession of a complete and valid certification of origin at the time of making a claim and meeting all recordkeeping obligations.

In order to provide the trade sufficient time to adjust to the new requirements and in consideration of the business process changes necessary to achieve full compliance, CBP may in appropriate cases, 4 show restraint in enforcement during the six-month period after USMCA’s entry-into-force. CBP will take into account the difficulties importers may face in complying with the new rules, as long as importers are making satisfactory progress toward compliance and are making a good faith effort to comply with the rules to the extent of their ability.

Implementation of the Agreement Between the United States of America, the United Mexican States, and Canada (USMCA) Uniform Regulations Regarding Rules of Origin.
This interim final rule is effective on July 1, 2020; comments must be received by August 31, 2020
 
Please contact us for any questions, our team well be ready to assist you.
 
Sincerely,