USMCA Rules of Origin for Goods Manufactured in Mexico

For a product manufactured in Mexico, USMCA eligibility depends on the applicable origin rule and supporting production facts. Depending on the rule, an importer or producer may need a classified Bill of Materials (BOM), manufacturing records, and cost calculations. Operating under a Mexican IMMEX program or holding a generic chamber-of-commerce certificate does not establish USMCA eligibility.

When a shipment enters the United States claiming USMCA preferential tariff treatment (Special Program Indicator S or S+ on CBP Form 7501), U.S. Customs and Border Protection (CBP) evaluates the claim under 19 U.S.C. § 4531, HTSUS General Note 11, and 19 CFR Part 182 (including the USMCA Uniform Regulations in Appendix A to Part 182).

Keep Marking, USMCA Preference, and Section 301 Separate:
U.S. customs law does not use a single origin test for Mexican imports that incorporate third-country materials. As illustrated in CBP Headquarters Rulings—including HQ H300226 (Sept 13, 2018), modified by HQ H301619 (Nov 6, 2018) and affirmed on reconsideration in HQ H305370 (Oct 11, 2019), as well as HQ H313369 (Sept 11, 2020) and HQ H327583 (Nov 15, 2022)—a product assembled in Mexico from Chinese subassemblies may qualify to be marked “Made in Mexico” under 19 CFR Part 102 (HQ H301619), or an entry from Mexico may qualify for USMCA tariff preference under a special provision such as General Note 11(p) (HQ H313369), while still owing 25% Section 301 duties on tariff lines covered by Chapter 99 U.S. Note 20 because no substantial transformation occurred in Mexico. Conversely, if a non-originating Chinese component fails the applicable General Note 11(o) tariff shift, CBP will deny the USMCA claim (HQ H327583).

Source check — November 12, 2026. The rule descriptions below were checked against USITC’s 2026 HTS Revision 23, General Note 11. The rates, tariff codes and holdings attributed to older rulings describe those cases at issuance. For a current entry, retain the applicable HTS revision, effective dates and any subsequent modification or revocation. Current GN 11 · HTS archive

1. Three Distinct Origin Frameworks: Marking, USMCA Preference, and Section 301

For goods exported from Mexico to the United States, distinguish country-of-origin marking, USMCA preferential treatment, and Section 301 trade-remedy origin. Other measures—such as Section 232 steel and aluminum tariffs or antidumping and countervailing duties (AD/CVD)—require separate product- and entry-date-specific analysis.

Does an antidumping or countervailing duty order cover the goods?

Identify the Commerce order and compare its written scope, including exclusions, with the physical product, producer, countries and processing steps. Record the entry date, relevant scope rulings or circumvention determinations, and the effective dates in the instructions. An HTS number can help locate an order. Its written scope controls. A marking decision, a USMCA certification or a Section 301 origin holding cannot resolve this separate question. Seek qualified review when the order or its application to the merchandise is unclear. Commerce AD/CVD guidance · Scope determinations

2. Core USMCA Chapter 4 Mechanisms (HTSUS General Note 11)

Making a USMCA preference claim generally requires possession of a valid certification of origin at the time the claim is made. Under 19 CFR § 182.14, a certification is not required for non-commercial importations or commercial importations whose originating goods have a value not exceeding $2,500 (unless CBP requires one under the anti-evasion provision in § 182.14(b)), though the goods themselves must still qualify as originating.

2.1 The Four Originating Criteria (Article 4.2 / Annex 5-A Element 7)

For an engineering decision flow and worked BOM scenarios, see USMCA Origin Criteria (A, B, C, D): Determining Eligibility & Completing Annex 5-A Element 7. The four criteria in Article 4.2 map to HTSUS General Note 11(b) as follows:

1. Criterion A — Article 4.2(a) / GN 11(b)(i): Wholly obtained or produced entirely in one or more USMCA countries within the categories of Article 4.3(a)–(l) (GN 11(l)). Because Article 4.3(l) covers goods produced exclusively from the wholly obtained goods listed in paragraphs (a)–(k), Criterion A is not limited to raw agricultural or mineral products.
2. Criterion B — Article 4.2(b) / GN 11(b)(iii): Produced entirely in one or more USMCA countries using non-originating materials, provided the good satisfies all applicable requirements, including its product-specific rule in Annex 4-B (GN 11(o)). Depending on the tariff classification, the rule may require a tariff shift, a Regional Value Content (RVC) threshold, a specific manufacturing process, or a combination.
3. Criterion C — Article 4.2(c) / GN 11(b)(ii): Produced entirely in one or more USMCA countries exclusively from originating materials. The certifier must possess information demonstrating that every incorporated material is originating (19 CFR § 182.12(f)), though the regulation does not prescribe a single mandatory supplier certificate format for every BOM line.
4. Criterion D — Article 4.2(d) / GN 11(b)(iv): Except for goods of Chapters 61–63, the good must be produced entirely in one or more USMCA countries. One or more non-originating materials provided for as parts must fail the product-specific rule because either (1) the good and those materials are classified in the same subheading or in a heading not further subdivided into subheadings, or (2) the good entered a USMCA country unassembled or disassembled but was classified as an assembled good under GRI 2(a). The good must also meet at least 60% RVC under the Transaction Value method or 50% under the Net Cost method, plus all other applicable requirements. Check the exact tariff treatment of the parts and the imported condition before using this criterion.

2.2 Product-Specific Tariff Shift Rules (USMCA Annex 4-B / GN 11(o))

Read the exact product-specific tariff-shift rule, including exceptions, excluded inputs and alternative RVC pathways. The required change is tested on the relevant non-originating materials against the classification of the finished good. Common forms include:

• Change in Chapter (CC): Non-originating inputs must be classified outside the finished product’s 2-digit HS Chapter.
• Change in Tariff Heading (CTH): Non-originating inputs must shift from a different 4-digit HS Heading.
• Change in Tariff Subheading (CTSH): Non-originating inputs must shift from a different 6-digit HS Subheading (often paired with an RVC alternative when shifting from a dedicated parts subheading).

Treatment of originating and unverified inputs: Originating materials do not need to undergo the tariff shift required of non-originating materials, provided their originating status is substantiated under 19 CFR § 182.12(f). A domestic Mexican purchase invoice or a Clave V1 virtual pedimento does not by itself prove that a material is originating. Any material of undetermined origin must be treated as non-originating in the tariff-shift and RVC analysis.

2.3 Regional Value Content (RVC) Formulas (USMCA Article 4.5 & HTSUS General Note 11(c))

When a product-specific rule in Annex 4-B (General Note 11(o))—or Criterion D—requires a minimum percentage of regional value content, USMCA Article 4.5 and HTSUS General Note 11(c) provide two calculation methods:

1. Transaction Value (TV) Method (Article 4.5.2): RVC = ((TV - VNM) / TV) × 100

   • TV: The transaction value of the good, adjusted to exclude costs incurred in the international shipment of the good as specified in General Note 11(c)(ii). Do not automatically deduct all post-factory expenses without checking whether they are international shipping costs.
   • VNM: The value of non-originating materials including materials of undetermined origin, used by the producer in the production of the good.

2. Net Cost (NC) Method (Article 4.5.3): RVC = ((NC - VNM) / NC) × 100

   • NC: Total cost—determined across applicable product, period, and other costs—minus the excluded costs enumerated in the statute: sales promotion, marketing and after-sales service costs, royalties, shipping and packing costs, and non-allowable interest costs. Costs must be allocated using a reasonable allocation method under General Note 11(c)(vii) and the Uniform Regulations (19 CFR Part 182, Appendix A). Total cost is not limited to direct factory labor and overhead, and it excludes profit.

RVC Thresholds Are Product-Specific Under General Note 11(o):
While Criterion D (Article 4.2(d)) and many Chapter 84 and 85 machinery rules (such as centrifugal pumps under 8413.70 [Chapter 84, Rule 40(B)] or industrial fans under 8414.59 [Chapter 84, Rule 47(B)]) specify 60% Transaction Value or 50% Net Cost, RVC percentages vary by tariff rule:

• Under HTSUS General Note 11(o), Chapter 85, rule for heading 8537 (control panels and taillight converter kits in heading 8537, examined in HQ H327583), Branch (B) specifies 50% Transaction Value or 40% Net Cost.
• Automotive goods are governed by separate provisions in General Note 11(k). Requirements differ across passenger vehicles, light/heavy trucks, core parts, principal parts, and complementary parts, including distinct staging, alternative methodologies, labor-value content (LVC), and vehicle-producer steel and aluminum purchasing rules. For example, HQ H350927 (October 9, 2025) analyzes an original-equipment automotive lamp rule offering a heading-shift pathway or a specified parts-shift pathway with a 75% TV / 65% NC threshold. Always verify the exact 6-digit HTSUS subheading in General Note 11(o) (or 11(k) for covered automotive goods) before running an RVC calculation.

2.4 The 10% De Minimis Rule (USMCA Article 4.12 & GN 11(e))

Under Article 4.12 and HTSUS General Note 11(e), a non-textile good that would otherwise fail to qualify solely because certain non-originating materials do not undergo the required tariff shift may still qualify as originating if the value of all such non-shifting non-originating materials does not exceed 10% of the adjusted transaction value (or 10% of the total cost of the good), and the good satisfies all other applicable requirements.

• Textile and Apparel Goods (Chapters 50–63 and heading 9619): Governed by separate weight-based and elastomeric-content de minimis rules under USMCA Chapter 6 (General Note 11(e)(iv)), not the general 10% value rule.
• Excluded or restricted inputs (Annex 4-A / GN 11(e)(ii)–(iii)): Check the specified dairy, agricultural and other input/product combinations in GN 11(e)(ii). For goods of Chapters 1–27, GN 11(e)(iii) also requires the non-originating material to be in a different subheading from the good. In addition, if the finished good is subject to an RVC requirement, the value of any de minimis non-originating materials must still be included in VNM when computing RVC (Article 4.12.2).

3. CBP CROSS Rulings on Mexican Assembly, Marking, USMCA, and Section 301

The rulings below illustrate how CBP applies these frameworks to specific fact patterns. Under 19 CFR § 177.9, a ruling applies to the transaction and facts set forth in the ruling request; it is not a blanket rule for an entire industry. Always check current HTSUS classifications, Chapter 99 notes, and any subsequent modifications before applying a ruling to a current shipment.

3.1 The Electric Motor Rulings: HQ H300226 (Sept 13, 2018), Modified by HQ H301619 (Nov 6, 2018) & Affirmed in HQ H305370 (Oct 11, 2019)

• Facts: Johnson Electric North America, Inc. imported brushed DC electric motors (HTSUS 8501.10.40, Model 1999-1020656EP, used in automotive power door locks) assembled at a facility in Zacatecas, Mexico from three Chinese subassemblies: a stator/rear housing assembly, a rotor/armature assembly, and an end cap assembly, each imported into Mexico under heading 8503.
• Procedural History: CBP issued HQ H300226 on September 13, 2018. After a request to modify overbroad language regarding the scope of the substantial transformation test, CBP issued HQ H301619 on November 6, 2018 formally modifying HQ H300226. On October 11, 2019, CBP issued HQ H305370, denying reconsideration and affirming HQ H301619.
• Holding:
  1. Country of Origin Marking (19 CFR Part 102): Because the Chinese motor subassemblies (8503.00) shifted to finished electric motors (8501) under 19 CFR § 102.20, the motors were products of Mexico for marking purposes and had to be marked “Made in Mexico.”
  2. Section 301 Tariffs (19 U.S.C. § 2411): Because Part 102 marking rules do not determine origin for Section 301 trade remedies, CBP applied the common-law substantial transformation test (Energizer Battery). Because the three Chinese subassemblies already had a pre-determined end-use and Mexican operations consisted of assembling pre-fabricated subassemblies without changing their essential character, no substantial transformation occurred in Mexico. The motors were marked “Made in Mexico,” yet remained products of China for Section 301 duty assessment (9903.88.01).

3.2 Component-Level Motor Manufacturing in Mexico: NY N302707 (March 18, 2019)

• Facts: In contrast to HQ H301619, the manufacturer in NY N302707 (issued March 18, 2019, following NY N301975) imported discrete Chinese components into Mexico and performed component-level production of the subassemblies, final motor assembly, and testing in Mexico to produce a DC motor (HTSUS 8501.31.2000).
• Holding: NY N302707 found that the discrete Chinese components underwent a substantial transformation in Mexico for Section 301 purposes. Its predecessor NY N301975 addressed country-of-origin marking and NAFTA eligibility. Both rulings predate USMCA and do not establish current USMCA eligibility for an unspecified motor BOM.

3.3 Independence of USMCA Preference and Section 301 (HQ H313369, Sept 11, 2020) vs. Tariff-Shift Denial (HQ H327583, Nov 15, 2022)

• General Note 11(p) USMCA Eligibility vs. Section 301 Duties — HQ H313369 (Sept 11, 2020, affirming HQ H312426 of Aug 7, 2020):
  • Facts: CBP reviewed Chinese-origin IT, power-supply, and telecommunications goods (HTSUS 8471.50.0150, 8471.70.4065, 8471.70.5065, 8471.70.6000, 8471.70.9000, 8471.80.1000, 8473.30.1140, 8473.30.1180, 8473.30.5100, 8504.40.6012, 8504.40.6018, 8517.62.0020, and 8517.62.0090) imported into a Mexican maquiladora where they underwent only logistical services—sorting, picking, packing, and shipping—without manufacturing operations, and were exported to the United States in the same condition.
  • Basis for USMCA Eligibility (General Note 11(p), not GN 11(b)): Because no manufacturing occurred in Mexico, CBP noted that the goods could not qualify under General Note 11(b). Instead, they were deemed originating solely under the special provision in HTSUS General Note 11(p) for enumerated automatic data processing and telecommunications tariff lines imported from a USMCA party, making them eligible for USMCA preference under General Note 3(c)(i).
  • Section 301 Holding and the 8517.62.00 Exception: CBP held that qualifying for USMCA preference under General Note 3(c)(i) does not exempt Chinese-origin goods from Section 301 duties. Under U.S. Notes 20(a) and 20(e) to Subchapter III of Chapter 99, Chinese-origin goods listed in U.S. Notes 20(b) and 20(f) remained subject to the 25% Section 301 duty (9903.88.01 / 9903.88.03) in addition to general rates—except for the goods classified under subheading 8517.62.00 (8517.62.0020 and 8517.62.0090), which CBP noted were not included on the applicable Section 301 lists in U.S. Note 20 at that time. HQ H313369 thus illustrates that USMCA tariff preference and Section 301 origin operate under separate legal rules, while reflecting a special General Note 11(p) logistical scenario rather than Mexican manufacturing under General Note 11(b).
• USMCA Preference Denied During a Trade Compliance Review — HQ H327583 (Nov 15, 2022, CURT Manufacturing LLC):
  • Facts: CURT Manufacturing LLC imported automotive T-connectors (Part No. 55418) and taillight converter kits (Part No. 59236) classified under HTSUS 8537.10 from Mexico. On its entry summaries, CURT claimed USMCA preferential treatment while listing China (CN) as the country of origin for Section 301 purposes. CBP noticed that combination during a Trade Compliance review.
  • Holding: On reviewing the BOM, CBP found that both products incorporated a non-originating Chinese printed circuit board (PCB) assembly classified in HTSUS 8537.10 (along with Chinese molded parts of 8538.90 in the T-connectors). Because the non-originating Chinese PCB (8537.10) shared the same 4-digit heading (8537) as the finished goods, it failed both Branch (A) (tariff shift to heading 8537 from any other heading except printed circuit assemblies or molded parts of 8538.90) and Branch (B) (shift from printed circuit assemblies or molded parts of 8538.90 plus 50% TV / 40% NC RVC) of HTSUS General Note 11(o), rule for heading 8537. CBP therefore denied USMCA preferential tariff treatment.

Which manufacturing facts would change the comparison?

Two CBP rulings illustrate why a buyer needs the process steps behind the words assembled in Mexico.

H301619 modified H300226 and was later reconsidered in H305370. Read the scope of the change in the subsequent text. For H338716, check CROSS and later Customs Bulletin notices for the decision and the specific issue before applying it to a new entry. A blank modification field cannot establish a ruling’s current effect. Neither decision in this comparison resolves an AD/CVD order.

Ask engineering which components arrive functional, which ones the Mexican plant actually makes, and which drawing and BOM revision describe the shipment. Record those differences beside the legal question each ruling addresses. For a new entry, have the importer check subsequent decisions and the rules in effect on the entry date before relying on a comparison. CBP motor ruling · CBP thermal management ruling

4. Connecting USMCA Origin Claims to Mexican IMMEX & Anexo 24 Records

CBP may initiate an origin verification by requesting information or questionnaires under 19 CFR § 182.72 and § 182.73. Under § 182.73(e)–(f), the standard response period is 30 calendar days, with the start date depending on whether the request is sent to the importer or to the exporter/producer and the method of delivery. Always check the deadline stated on the actual CBP Form 28 notice and any applicable extension. Under § 182.75(c)(1), specified proposed denials require CBP to seek information from the certifying exporter or producer when the importer’s response is insufficient. Under § 182.75(c)(3), an intent-to-deny notice provides 30 days to submit additional information before the determination. Read the applicable ground, recipients and dates in the notice. CBP origin-verification regulations

For goods manufactured in a Mexican IMMEX plant, three record sets typically support an origin review:

1. Anexo 24 inventory records: Used to reconcile temporary imports (Pedimento Clave IN) and production consumption against finished exports (Pedimento Clave RT). Specific system requirements depend on the manufacturer’s regime and registrations. An Anexo 24 inventory balance helps trace materials, but does not by itself establish that an Annex 4-B origin rule is met.
2. Article 2.5 and Mexican duty records: Where USMCA Article 2.5 applies, Mexican duty deferral or drawback on non-originating inputs exported to the United States or Canada is limited by the lesser-of-two-duties formula in Article 2.5.1, subject to the exceptions in Article 2.5.6(a)–(g) and Mexican domestic implementation (Ley Aduanera Art. 63-A and applicable RGCE rules). Confirm applicable Mexican import duties (IGI), PROSEC or Regla Octava authorizations, and any Pedimento Clave CT filing deadlines with a licensed Mexican customs specialist.
3. Certification and origin substantiation: Maintain the production, purchasing, and cost documentation required by 19 CFR § 182.12(f) and § 182.15 (or USMCA Article 5.8 for Mexican exporters and producers) for at least five years.

Connect this task to the US entry

• Choose the origin purpose and build the factory fact packet
• Research comparable CBP rulings and their modification history
• Prepare an AD/CVD scope review