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USMCA Rules of Origin: What the Certification Needs

USMCA has no required certificate of origin form: CBP lists nine data elements, and the importer, exporter or producer may certify.

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The USMCA rules of origin decide whether a good qualifies as originating in the United States, Mexico or Canada, and so whether an importer can claim preferential (reduced or zero) duty treatment under the agreement. This guide is for import and procurement staff and compliance officers who need to know what a USMCA “certificate of origin” actually is. It is general information, not customs or legal advice.

Short answer

Under USMCA there is no required certificate of origin form. U.S. Customs and Border Protection (CBP) states that a claim for preferential treatment should contain nine minimum data elements, which can appear on an invoice or any other document. Only the producer, exporter or importer may complete the certification, and a valid certification is accepted for four years after it was completed (checked 2026-11-01).

What the rules of origin decide

USMCA entered into force on July 1, 2020 and replaced NAFTA. Its product-specific rules of origin set the test a good must meet to be “originating”. A tariff shift test asks whether non-originating materials changed tariff classification during production. On textiles, CBP says the revised tariff shift rules “maintain the basic concepts established under NAFTA with a few modifications”. For automotive goods, CBP notes that regional value content rises from 62.5% to 75%, phased in over three years. The product-specific rule for any other good must be looked up for that good, which this guide does not cover.

Origin for preferential duty is a different question from the origin used for marking or for government purchasing. See country-of-origin marking for imported medical devices, the substantial transformation test and Trade Agreements Act compliance, each of which applies its own rule.

USMCA certification of origin: the nine elements

Searches for a “USMCA certificate of origin form” or “template” usually expect a government form. CBP says no such form is required, and the older CBP Form 434 is no longer in use. What matters is that the document carries the nine minimum data elements listed in Annex 5-A of the agreement, per CBP:

  1. The certification type: whether the importer, exporter or producer is certifying
  2. The certifier
  3. The exporter
  4. The producer
  5. The importer
  6. A description of the good and its HS classification
  7. The origin criterion the good meets
  8. The blanket period, if applicable
  9. An authorized signature and date

Under 19 CFR 182.12, the certification also carries a statement beginning “I certify that the goods described in this document qualify as originating.” Because CBP does not prescribe a layout, a template is a convenience, not a required form. CBP says it has made an optional certification of origin template available on its website for USMCA and other trade agreements.

Who can certify, and for how long

Question Answer Source
Who may complete the certification? The importer, exporter or producer of the good 19 CFR 182.12(f)(1); CBP USMCA FAQs
Can CBP require a producer or exporter to certify? No; they may choose to provide one to customers CBP USMCA FAQs
How long is a valid certification accepted? Four years following the date it was completed 19 CFR 182.12(h)
How long can a blanket period run? Not exceeding 12 months from the date of certification 19 CFR 182.12(a)(4), (g)(2)

Where it matters for labs, clinics and supply imports

Labs and clinics that import instruments, consumables or supplies themselves, or buy from a supplier who imports, may encounter a request for the certification when a duty preference is claimed. Because only the producer, exporter or importer can complete it, a distributor that is none of these cannot issue one, per CBP. Importing medical products also brings separate FDA requirements, covered in importing medical devices into the US.

Common misunderstandings

  • “There is an official form to download.” No. CBP says there is no required certificate of origin form for USMCA.
  • “The exporter must always certify.” No. The importer, exporter or producer may certify, and CBP cannot require a producer or exporter to do so.
  • “A certificate lasts forever.” No. Acceptance runs four years from completion, and a blanket period is capped at 12 months.

FAQ

What is a USMCA certificate of origin?

It is the certification of origin supporting a claim for preferential treatment. CBP uses the term “certification of origin” and expects nine minimum data elements, not a set form.

Is there a USMCA certificate of origin form or template?

No required form exists. A document that contains the nine elements, such as an invoice, can carry the claim.

Who completes the certification?

The producer, exporter or importer, and no one else.

How long is a certification valid?

Under 19 CFR 182.12(h), a properly completed, signed and dated certification is accepted as valid for four years from the date it was completed. A blanket period within it cannot exceed 12 months.

Sources

  • U.S. Customs and Border Protection, USMCA FAQs: https://www.cbp.gov/trade/priority-issues/trade-agreements/free-trade-agreements/USMCA/FAQs (checked 2026-11-01)
  • 19 CFR 182.12, Certification of origin, via Cornell LII: https://www.law.cornell.edu/cfr/text/19/182.12 (checked 2026-11-01)

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