Case Study

Ensuring USMCA Compliance for a U.S. Importer

Client Background

Our client, a U.S.-based industrial product wholesaler, imports components from a supplier in Mexico and seeks to determine whether their products qualify as originating under the United States-Mexico-Canada Agreement (USMCA). They needed assistance navigating the complex country-of-origin requirements to ensure compliance and maximize the benefits of duty-free treatment.

Challenges

1. Complex Supply Chain: The client’s supply chain involves multiple components and materials of varying origins, requiring a thorough analysis of the product’s eligibility under USMCA rules.

2. Documentation Requirements: The client lacked a structured process for gathering the necessary information, including a detailed Bill of Materials (BOM) and cost breakdowns.

3. HTS Classification: Accurate Harmonized Tariff Schedule (HTS) classification for all materials was required to assess compliance with USMCA provisions.

Solutions Provided

1. Information Organization and Preparation

  • Assisted the client in gathering all necessary documentation, including the Bill of Materials (BOM), supplier declarations, and transactional data.
  • Guided the client in organizing information required for HTS classification, ensuring all components and materials were accurately documented.

2. BOM Analysis and Country of Origin Data Collection

  • Reviewed the BOM and provided a standardized template to capture critical information about the origin of each material.
  • Worked with the client to obtain detailed country-of-origin information for all inputs and cost data for the finished product.

3. HTS Classification and Rule Application

  • Assisted the client in determining the HTS codes for each material in the BOM and the finished product, ensuring accurate classification for compliance analysis.
  • Applied the USMCA rules of origin to assess compliance, using the transaction value methodand the net cost method to calculate qualifying ratios.

4. Compliance Analysis and Documentation

  • Prepared a comprehensive country of origin analysis according to USMCA provisions, supported by certificates, transaction values, and detailed calculations.
  • Ensured all necessary records were in place to demonstrate compliance with reasonable care and diligence, mitigating the risk of non-compliance.

Results

1. USMCA Qualification: Confirmed that the client’s product qualified for duty-free treatment under USMCA provisions, resulting in significant cost savings.

2. Streamlined Compliance Process: Provided the client with a structured framework and templates for future origin determinations, reducing administrative burdens.

3. Enhanced Confidence: Equipped the client with thorough documentation and supporting analysis, ensuring smooth communication with Customs and Border Protection (CBP) in case of audits or inquiries.

If you need assistance with USMCA compliance or other trade-related challenges, contact us today to ensure your business stays compliant and competitive in the global marketplace.

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