CUSMA (USMCA) Guide for Canadian Importers: Rules of Origin and What Changed

What CUSMA Means for Goods Imported Into Canada

The Canada-United States-Mexico Agreement entered into force on July 1, 2020, replacing the North American Free Trade Agreement. It is called USMCA in the United States and T-MEC in Mexico; the rules are the same agreement.

For an importer, CUSMA's value is the preferential tariff treatment it gives qualifying goods. There are two: the United States Tariff (UST) and the Mexico Tariff (MXT). Which one applies depends on the country of last production, other than a minimal operation. The old Mexico-United States Tariff (MUST) no longer exists.

A few things CUSMA does not do: it does not remove GST on imported goods, it does not change anti-dumping or countervailing measures, and it does not exempt goods from the surtaxes Canada has placed on U.S.-origin goods (see What Changed in 2026).

Rules of Origin: How a Good Qualifies

Shipping a product from a U.S. warehouse does not make it a CUSMA good. Under the agreement's rules of origin, a good is "originating" in one of three ways:

• It is wholly obtained or produced in Canada, the U.S. or Mexico, such as minerals extracted or crops grown there
• It is produced in the CUSMA countries entirely from originating materials
• It is produced using non-originating materials and meets the product-specific rule of origin for its tariff classification

Product-specific rules

Most manufactured goods qualify under the third route. The product-specific rules in Annex 4-B of CUSMA are set by tariff classification, which is why tariff classification comes first. A rule usually requires one or both of the following:

• A change in tariff classification: the non-originating materials must be transformed enough that they classify under a different heading or subheading than the finished good
• Regional value content: a minimum share of the good's value must come from the CUSMA region, calculated by the transaction value method or the net cost method set out in the rule

De minimis

A good can still qualify when a small share of non-originating materials does not meet the required change in tariff classification. Under CUSMA, that share generally can be up to 10% of the good's transaction value or total cost, with exceptions for some goods.

Automotive goods

Vehicles and auto parts have stricter rules than NAFTA had, including higher regional value content for passenger vehicles and light trucks, requirements for North American steel and aluminum, and a labour value content requirement. Vehicle and parts importers should check the specific rule for each tariff item rather than relying on the general rules above.

Shipping through a third country

A good keeps its originating status if it passes through a country outside CUSMA only while it stays under customs control there and undergoes nothing beyond unloading, reloading, storage, labelling required by Canada, or operations needed to preserve it or move it. CBSA may ask for bills of lading and customs documents that show the route.

Which Goods Qualify and Which Usually Don't

Origin follows where a good was made and what it was made from. As a general guide:

Usually qualifies when the rule is met

• Goods grown, mined or harvested in the U.S. or Mexico
• Goods manufactured in the U.S. or Mexico from North American materials
• Goods manufactured in the U.S. or Mexico from imported components that are transformed enough to meet the product-specific rule

Usually does not qualify

• Goods made overseas and only stored, repacked or relabelled in the U.S.
• Goods whose non-originating content exceeds what the rule allows
• Goods with no certification of origin, or information that can't support one, when the value is over the $3,300 threshold

Country of origin for CUSMA purposes is not always the same as country of origin for marking. That difference matters in 2026, because Canada's surtaxes use the marking rules (see below).

The Certification of Origin

To claim CUSMA preference, the importer must have a certification of origin in its possession at the time the claim is made, and provide it to CBSA on request. Unlike NAFTA, CUSMA has no prescribed certificate form.

• Who can complete it: the exporter, the producer or the importer. An importer certifying must have information, including documents, showing the good is originating
• Where it goes: on an invoice or any other document; it can be completed, signed, submitted and stored electronically
• What it covers: a single shipment, or multiple shipments of identical goods over a blanket period of up to 12 months
• When it is not required: CBSA does not require one where the value for duty is $3,300 or less; conditions apply (Customs Notice 20-15)

The certification must contain CUSMA's minimum data elements, set out in Annex 5-A:

• Whether the certifier is the importer, exporter or producer
• The certifier's name, title, address, telephone and email
• The exporter's details, if different from the certifier
• The producer's details, if different from the certifier or exporter
• The importer's details, if known
• A description of the good and its six-digit HS classification
• The origin criterion the good meets
• The blanket period, if any
• An authorized signature, date and the certification statement

A NAFTA certificate of origin cannot support a CUSMA claim.

Claiming CUSMA, Fixing Missed Claims and Keeping Records

1. Classify the good and find its rule

   The HS classification determines which product-specific rule applies. Confirm it before relying on a supplier's origin statement.

2. Get or prepare the certification of origin

   Have it in hand before the goods are accounted for. For recurring shipments of identical goods, ask the supplier for a blanket certification.

3. Claim UST or MXT on the declaration

   The tariff treatment is claimed when the goods are accounted for. Your customs broker enters it on the declaration when the goods qualify.

4. Claim missed preference within four years

   If CUSMA treatment was not claimed at the time, CBSA allows four years from the date the goods were accounted for to claim it and request a refund of the duty overpaid.

5. Keep the records

   Keep the certification and the documents behind it. CBSA verifies origin claims under its free trade agreements, and a claim that can't be supported has to be corrected. See How to Avoid Customs Penalties in Canada.

When origin is genuinely uncertain, an importer can ask CBSA for an advance ruling on origin before importing.

What Changed in 2026

The July 1 joint review: annual reviews instead of a 16-year extension

CUSMA requires the three countries to hold a joint review on its sixth anniversary. At the review on July 1, 2026, the United States did not agree to extend the agreement for a new 16-year term; Canada's trade minister reaffirmed Canada's support for renewal. Under Article 34.7, the countries now review the agreement every year. If they never agree to extend it, CUSMA ends on July 1, 2036.

Nothing changed at the border on July 1. The agreement remains in force, and its rules of origin, certification requirements and preferential tariff treatment work as before.

Canada's September 8 surtax on U.S.-origin goods

Since September 8, 2026, Canada has charged a surtax of 15%, 25% or 50% of the value for duty on listed goods originating in the U.S., under the United States Surtax Order (2026). For the surtax, U.S. origin means goods eligible to be marked as goods of the U.S. under the marking rules, not CUSMA's rules of origin. The surtax is in addition to customs duty, so claiming UST does not remove it, and it applies even to shipments under de minimis thresholds.

On the same date, the surtax on some U.S. steel and aluminum goods rose from 25% to 50%. Goods already in transit to Canada on September 8 are not subject to the new surtax when the importer can prove it. The details are in CBSA Customs Notice 26-23 and the Department of Finance's list of products.

U.S. tariffs on Canadian goods

Going the other way, the 50% U.S. Section 338 tariffs that took effect on August 22, 2026 apply to listed Canadian goods even when they qualify for USMCA. That affects Canadian businesses shipping south rather than imports into Canada.

These measures change often. Our industry news page tracks updates that affect Canadian importers.

How Garden City Helps

Origin and tariff treatment are part of every customs declaration. As a licensed Canadian customs broker, Garden City Customs Services Inc. reviews country of origin, tariff treatment and free trade agreement eligibility when preparing customs declarations, and supports classification and compliance reviews for businesses with complex or high-volume imports.

Official Sources

• CBSA: The Canada-United States-Mexico Agreement, what importers need to know
• CBSA: Certifying the origin of goods under CUSMA
• CUSMA Chapter 5: Origin procedures (Global Affairs Canada)
• CBSA Customs Notice 26-23: United States Surtax Order (2026)
• Department of Finance: U.S. products subject to counter-tariffs from September 8, 2026
• Global Affairs Canada: Statement following the CUSMA joint review meeting