Interim Final Rule for USMCA Implementing Regulations


Trade Update • Jan 21, 2025

Flags of Canada, Mexico, and United States (USMCA Agreement Concept)
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n January 17, 2025, the Federal Register published an Interim Final Rule (IFR) introducing new regulations under Title 19 of the Code of Federal Regulations (19 CFR 182) to implement provisions of the United States-Mexico-Canada Agreement (USMCA). These regulations cover several key areas, including automotive goods, textile and apparel goods, drawback and duty-deferral programs, recordkeeping, protest requirements, and temporary admission of goods.

The new rules are effective as of March 18, 2025, with a delayed compliance date of May 19, 2025, for vehicle certification requirements to allow producers time to adjust.

Key Details of the Interim Final Rule

1. Automotive Goods Regulations

The IFR establishes detailed certification requirements for the production of covered vehicles, including passenger vehicles, light trucks, and heavy trucks. Compliance with USMCA preferential tariff treatment relies on meeting the following conditions:

  • Labor Value Content (LVC): Detailed Certificate Requirement
  • Steel Purchasing Requirements: Detailed Certificate Requirement
  • Aluminum Purchasing Requirements: Detailed Certificate Requirement

Vehicle producers must submit these certifications via the USMCA Automotive Certification Portal (https://trade.cbp.gov/USMCA/s/) at least 90 days before the start of the certification period.

Each certification submission generates a unique identifier, which must be included in entry summary documents to claim preferential tariff treatment.

Alternative Staging Regime: Producers qualifying for exemptions under the alternative staging regime must submit separate certifications detailing compliance with the modified rules.

2. Textile and Apparel Goods Regulations

New provisions for tariff preference levels (TPLs) have been introduced under USMCA Chapter 6. Key updates include:

  • TPL administration will require a certificate of eligibility instead of a certification of origin.
  • Verification of textile and apparel goods can be conducted via site visits under USMCA Article 6.6.

3. Drawback and Duty-Deferral Programs

The IFR aligns drawback and duty-deferral regulations with USMCA commitments. Updates in Subpart E of 19 CFR 182 clarify these programs for goods traded between USMCA countries.

4. Recordkeeping and Protest Requirements

Revised under 19 CFR 163 and 19 CFR 174, recordkeeping and protest rights have been extended to include USMCA-specific requirements. Importers and producers must maintain documentation for compliance with the agreement’s provisions.

5. Temporary Admission of Goods

The IFR updates provisions in 19 CFR 10, aligning with USMCA Article 2.7. Goods temporarily admitted into USMCA territories can now benefit from duty-free treatment under specified conditions.

Compliance Deadlines and Certifications

  • Effective Date: March 18, 2025.
  • Vehicle Certification Deadline: May 19, 2025, for compliance with the 90-day submission requirement.
  • Vehicle certifications submitted before May 19, 2025, are exempt from the 90-day rule.

Certification Process:

  1. Submit LVC, steel purchasing, and aluminum purchasing certifications via the USMCA Portal.
  2. Include the unique identifier in entry summary documents to claim preferential treatment.
  3. Meet the specific conditions for alternative staging regimes if applicable.

Implications for Trade and Industry

The updated regulations emphasize transparency and compliance across industries, particularly in automotive and textile sectors. By introducing unique certification identifiers and detailed procedural requirements, the IFR strengthens the enforcement of USMCA rules.

Trade professionals must familiarize themselves with these updates and adjust their compliance processes accordingly. The full text of the IFR, along with additional resources, is available through the following links:

How GHY Can Help?

Navigating the complex changes introduced by the USMCA Interim Final Rule can be challenging, but we are here to help. GHY provides comprehensive support, including ensuring compliance with USMCA requirements, streamlining certification submissions for Labor Value Content (LVC), steel, and aluminum, managing unique identifiers for entry documents, and assisting with Tariff Preference Level (TPL) requirements for textiles.

Additionally, GHY offers guidance on filing protests, maximizing duty deferral programs, and tailoring solutions to your specific trade needs. With decades of expertise, GHY is your partner in achieving seamless compliance and navigating today’s regulatory landscape.

Contact Us Today! gts@ghy.com, or call +1 (800) 667-0771.

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