How to file with CBP, USMCA’s Auto Certifications - LVC, Steel, Aluminum Certifications


In addition to the certification of origin, producers of passenger vehicles, light trucks, and heavy trucks are required to submit three new certifications to receive preferential tariff treatment under the USMCA for these goods – Labor Value Content (LVC) certification (Annex B), Steel certification, (Annex C) and Aluminum certification (Annex D).


The USMCA certifications include the following four types of certifications:

  • Certification of origin for all commodities– See Annex A for the required minimum data elements;

  • Labor Value Content Certification for passenger vehicles, light trucks, and heavy trucks – See Annex B for the required minimum data elements;

  • Steel Certification for passenger vehicles, light trucks, and heavy trucks – See Annex C for the requirement minimum data elements; and

  • Aluminum Certification for passenger vehicles, light trucks and heavy trucks – See Annex D for the required minimum data elements.


In accordance with the Phase 1 Implementation Policy, automotive producers, exporters, and importers are allowed until December 31, 2020 to obtain and submit necessary certifications and documentation, including any documentation necessary to establish compliance with the RVC requirement, for 2020.


A passenger vehicle, light truck, or heavy truck is eligible for preferential tariff treatment only if the producer provides to CBP the required LVC certification, steel certification, aluminum certification, and has information on record to support those calculations relied on for the certifications. However, as described previously, CBP will permit automotive producers, exporters, and importers to obtain and submit the necessary certifications and documentation, including any documentation necessary to establish compliance with the RVC requirement, by December 31, 2020 for claims of preferential tariff treatment of qualifying passenger vehicles, light trucks, or heavy trucks entered for consumption or withdrawn from warehouse for consumption, on or after July 1, 2020 and through the end of calendar year 2020. For subsequent LVC certification, steel certification, and aluminum certification, CBP will provide additional guidance on the timing and submission of such certifications.


LVC, Steel, and Aluminum certification can be filed through the USMCA Center’s portal at CBP’s website www.cbp.gov/usmca

Producers can upload files and submit their automotive certifications using the following steps:


Step 1: From the webpage: • Click on Automotive Certification Request.


Step 2: Contact Information:

  • Select from the drop down menu Producer

  • Click next to advance.

Step 3: Upload File:

  • Select the checkbox for the type of automotive certification documents you wish to include in the submission.

  • Select the files you wish to upload and click next to submit. Please do not mix Steel, Aluminum, and LVC in one file; however, you can upload three separate files in one submission.

Upon completion of the submission you will receive a confirmation message and a tracking number. A USMCA Portal User Guide can be found on the webpage: www.cbp.gov/usmca, which includes the steps summarized above with screenshots and troubleshooting tips. If the above portal is down an alternative method for submitting these certifications is to email them to USMCAautoRoO@CBP.DHS.gov The USMCA Center will reply to sender within two business days acknowledging receipt of the email and a tracking number.


LVC Certification Review for Errors and Omissions

The USMCA Center will submit the LVC certification to DOL for review for omissions and errors within five business days from acknowledging receipt of the producer certification.

DOL will review the LVC certification within 60 days and respond to CBP with status of their review - either “no errors” or “errors found.”


  1. If the USMCA Center receives “no errors” status from DOL, then the USMCA Center will accept the certification and reply to the producer, “certification accepted.”

  2. If the USMCA Center receives “errors found” status, accompanied by a description of the errors or omissions from DOL, then CBP will reply to the producer, “certification rejected,” describe the errors and omissions, and give the producer an opportunity to supply further information. CBP will inform the producer that further information or documentation is due to CBP in five business days.

  3. Producer should resubmit a revised certification to CBP via the USMCA Center. The USMCA Center will coordinate review with DOL.

  4. DOL will review the new documentation for omissions and errors within 30 days and reply to the USMCA Center with their determination.

  5. If the USMCA Center receives “no errors” status form DOL, CBP will accept the certification and reply to the producer, “Certification accepted.”

  6. If the USMCA Center receives “errors found” status from DOL, then CBP will reject the LVC certification and the USMCA Center will reply to the producer with “certification not properly filed.”

If producer received a “certification not properly filed”, a new certification package must be submitted to CBP via the USMCA Center Portal. Users will need to resubmit their documents through the portal using the initial procedure. Please note each individual submission will receive an individual tracking number.


Steel and Aluminum Certification Review for Errors and Omissions

The USMCA Center will review the steel certification and aluminum certification for errors and omissions and determine “no error” status or “errors found” status and the description of the errors or omission


  1. If “no errors” found, the USMCA Center will accept the certification and reply to the producer, “Certification accepted.”

  2. If “errors found,” the USMCA Center will reply to the producer with a notification that “certification rejected” and a description of the errors or omissions for action. The USMCA Center will inform the producer that further information or documentation is required and additional information is due to CBP in five business days.

  3. The producer should submit a revised certification to CBP via the USMCA Center. The USMCA Center will review the revised certification for omissions and errors within 30 days.

  4. If “no errors” found, the USMCA Center will accept the Steel or Aluminum certification.

  5. If “errors found,” the USMCA Center will reject the Steel or Aluminum certification and will reply to the producer with “certification not properly filed.” Users will need to resubmit their documents through the portal using the initial procedure. Please note each individual submission will receive an individual tracking number.

The USMCA Center will notify producers of the status of each certification upon completion of the Center’s review. Upon receipt of final documentation and within 120 days of initial submission, CBP will inform the producer if their certifications are “properly filed” and have been “accepted.”

If CBP determines that the producer’s certifications are “not properly filed,” the producer must resubmit a new package for review via the USMCA Center Portal using the initial how to file process. Until such point that CBP has determined that the producer’s certifications are “not properly filed,” the producer may continue to submit claims for preferential tariff treatment of qualifying passenger vehicles, light trucks, and heavy trucks.


Auto RVC and LVC Averaging Election Requirements for Passenger Vehicles, Light Trucks, and Heavy Trucks

For the purpose of calculating the regional value content or labor value content of a passenger vehicle, light truck, or heavy truck, the producer may elect to average its RVC or LVC using any of the following categories, on the basis of either all motor vehicles in the category or only those motor vehicles in the category that are exported to the territory of one or more of the other USMCA countries:

a)  the same model line of motor vehicles in the same class of vehicles produced in the same plant in the territory of a USMCA country;


b)  the same class of motor vehicles produced in the same plant in the territory of a USMCA country;


c)  the same model line or same class of motor vehicles produced in the territory of a USMCA country; or


d)  any other category as the USMCA countries may decide.


For purposes of calculating the RVC of passenger vehicles, light trucks, or heavy trucks, the calculation may be averaged over the producer’s fiscal year.

For purposes of calculating the LVC of passenger vehicles, light trucks, or heavy trucks, the producer may base the LVC calculation on the following periods:

a) the previous fiscal year of the producer; b) the previous calendar year; c) the quarter or month to date in which the vehicle is produced or exported; d) the producer’s fiscal year to date in which the vehicle is produced or exported; or e) the calendar year to date in which the vehicle is produced or exported.

Producers are allowed until July 31, 2020 to submit RVC and LVC averaging elections for 2020. See Annex E and Annex F. Producers should submit their RVC and LVC averaging documentation to the Portal at CBP’s website www.cbp.gov/usmca Users can submit their RVC and LVC averaging documentation using the following steps:


Step 1:

  • From the webpage, click on Automotive Certification Request.


Step 2:

  • Contact Information: Select from the drop down the certifier type.

  • Enter in certifier information. Click next to advance.

Step 3:

  • Upload File: Select the checkbox for election. You can upload both the RVC election and the LVC election in one submission. We do request users have the two documents separated at the time of submission.

Upon completion of the submission, users will receive a confirmation message and a tracking number. A USMCA Portal User Guide can be found on the webpage: www.cbp.gov/usmca, which includes the steps summarized above with screenshots and troubleshooting tips.

If the above website is down an alternative method for submitting the RVC and LVC Averaging election documentation is to email them to USMCAautoRoO@CBP.DHS.gov The USMCA Center will reply to sender within two business days acknowledging receipt of the email and a tracking number.


Alternate RVC and LVC Averaging Periods for Passenger Vehicles, Light Trucks, and Heavy Trucks

If the fiscal year of a producer begins after July 1, 2020, but before July 1, 2021, the producer may calculate its RVC or LVC of passenger vehicles, light trucks, or heavy trucks for the period beginning on July 1, 2020 and ending at the end of the following fiscal year.

For the period July 1, 2020 to June 30, 2023, the producer may calculate its RVC or LVC of passenger vehicles, light trucks, or heavy trucks for the following periods:

a) July 1, 2020 to June 30, 2021; b) July 1, 2021 to June 30, 2022; c) July 1, 2022 to June 30, 2023; and d) July 1, 2023 to the end of the producer’s fiscal year.

Additionally, a producer may calculate its RVC or LVC of heavy trucks for the following periods:


a) July 1, 2023 to June 30, 2024; b) July 1 2024 to June 30, 2025; c) July 1 2025 to June 30, 2026; d) July 1 2026 to June 30, 2027; and e) July 1, 2027 to the end of the producer's fiscal year.

Correction of False/Unsupported USMCA Claims

An importer will not be subject to penalties under 19 USC 1592 for making an incorrect claim that a good qualifies as a USMCA originating good if the importer, in accordance with the prescribed regulations, makes a corrected claim within 30 days of discovery and pays any duties and MPF owed with respect to that good.


Recordkeeping Requirements

Any importer who claims preferential tariff treatment under the Agreement for a good imported into the United States from a USMCA country must keep the following documentation for a period of no less than five years from date of entry:


  1. Records and supporting documentation related to the importation;

  2. All records and supporting documents related to the origin of the good (including any certifications or copies thereof); and

  3. Records and supporting documentation necessary to demonstrate compliance with the transit and transshipment provisions in Article 4.18 of the Agreement. The importer must render these records for examination and inspection upon request per 19 USC 1508 –1510 and 19 CFR Part 163.6.

Any exporter or producer who completes a USMCA certification of origin or provides a written representation for a good exported from the United States to a USMCA country must keep all records and supporting documents related to the origin of the good (including the certification or copies thereof), including records related to:

1. the purchase, cost, value, and shipping of, and payment for, the good or material; 2. the purchase, cost, value, and shipping of, and payment for, all materials, including indirect materials, used in the production of the good or material; and 3. the production of the good in the form in which is exported or the production of the material in the form in which it was sold.

These records must be maintained for a period of no less than five years from date of entry and must be rendered for examination and inspection upon request.

In addition to the recordkeeping requirements denoted above, any vehicle producer, whose good is the subject of a claim for preferential tariff treatment under the USMCA, must keep records and supporting documents related to the labor value content and steel and aluminum purchasing requirements.

The vehicle producer must retain these records for a period of five years after the date of filing the certifications and render them for examination and inspection upon request. It is anticipated that the U.S. Department of Labor will issue regulations addressing in more detail recordkeeping requirements related to the high-wage components of the labor value content requirements.

The requirement on the importer, exporter, and producer to maintain records applies even if the importing Party does not require a certification of origin or if a requirement for a certification of origin has been waived.


Verification by CBP Pursuant to Article 5.9 of the USMCA, CBP may conduct a verification to determine whether a good entered with a claim for preferential tariff treatment qualifies as originating by one or more of the following:

(1) a written request or questionnaire, such as a CBP Form 28, Request for Information, seeking information, including documents, from the importer, exporter, or producer of the good;

(2)  a verification visit to the premises of the exporter or producer of the good in order to request information, including documents, and to observe the production process and the related facilities;


(3)  for a textile or apparel good, the procedures set out in Article 6.6 of the Agreement; or


(4)  any other procedure as may be decided by the USMCA countries.


CBP may initiate the verification to the importer or to the person who completed the certification of origin. If CBP initiates a verification to the exporter or the producer, it will inform the importer of the initiation of the verification.

If CBP requests information from the importer and the importer does not provide sufficient information to demonstrate that the good is originating, and the importer was not the certifier, CBP shall request information from the certifier (i.e., exporter or producer) before it may deny the claim for preferential treatment.

When conducting a verification, CBP will accept information, including documents, directly from the exporter, producer, or importer.

As each verification involves a unique set of facts and the requirements of product-specific rules differ widely, CBP does not provide an all-inclusive list of documents required to substantiate that a good qualifies as an originating good. Information that may be helpful during a verification includes but is not limited to the following:

  • Flow-charts, technical specifications and other documents explaining the manufacturing process.

  • An explanation of how the good meets the specific rule of origin in GN 11;

  • A bill of materials showing the classification number, origin, and cost of each material;

  • Certifications or affidavits from the producer of each originating material attesting to the country of manufacture and its originating status;

  • Purchase orders and proof of payment to substantiate values;

  • Documentation pertaining to assists, inventory management methods, indirect materials, etc.;

  • Raw materials invoices;

  • Production records; and

  • Export documents.

If CBP intends to deny preferential tariff treatment based on information submitted during the verification, CBP will inform the importer, and any exporter or producer who is the subject of the verification and provided information during the verification. CBP will allow additional information to be submitted 30 days after CBP has informed the USMCA countries of its intent to deny the claim.

Verification for the Automotive Commodities

CBP recognizes that importers of automotive commodities (i.e., passenger vehicle, light trucks, heavy trucks, and parts thereof) may need additional time to adjust business practices in order to demonstrate compliance with new requirements under the USMCA, particularly relating to the preferential tariff treatment of goods. In order to provide vehicle producers and auto parts producers, as well as importers and exporters of vehicles and auto parts, adequate time to adjust to the new requirements and, in consideration of the business process changes that may be necessary to achieve full compliance, CBP will allow additional time to respond to a verification (CBP Form 28, Request for Information) for the first 12 months of entry into force.


Issuing a Determination

CBP will provide the importer, exporter, or producer that certified the good is originating and is the subject of a verification, with a written determination of origin, either positive or negative, that includes the findings of facts and the legal basis for the determination. If the importer is not the certifier, CBP will also provide the written determination to the importer.

If the importer provides CBP with sufficient information to demonstrate the goods qualify as originating, CBP will notify the importer via a CBP Form 29-Notice of Action. If the certification of origin of a good that is the subject of a verification, is completed by the exporter or producer of the good, CBP will also notify the exporter or producer. The CBP Form 29 will indicate the positive determination, and include the HTSUS number, description of the good, and the rule of origin that applies to the good.


If the importer does not adequately substantiate the claim, CBP will notify the importer, and any exporter or producer who is subject to the verification and who provided information during the verification, via a CBP Form 29, Notice of Action, “Proposed Action.” The importer and any other party receiving the notice will have 30 days to submit additional information to substantiate that the imported goods meet the requirements for preferential duty treatment under USMCA. (Article 5.9.16)

If CBP does not receive additional information supporting the claim for preferential treatment within 30 days, CBP will issue a negative determination to the importer, and the exporter or producer, as appropriate, via a CBP Form 29, Notice of Action, “Action Taken.” CBP will deny the preference claim and liquidate the entries with the applicable duties, taxes, and fees.

Impact of a Negative Determination on a Blanket Certification

If a preference claim is made on a good covered by a blanket certification, and a negative determination is issued, CBP shall deny preference to all importations of identical goods covered by that blanket certification and liquidate the entries with the applicable duties, taxes and fees. Pattern of Conduct

When CBP finds through pattern of conduct (Article 5.9.17) that an importer continues to claim preference on a good previously the subject of a negative determination, CBP may deny preference on identical goods imported by such importer until compliance with the rules of origin is established.

When the verifications indicate a pattern of conduct by an exporter or a producer of false or unsupported representations that a good qualifies as an originating good, CBP may deny preferential tariff treatment from identical goods exported or produced by such entity, until compliance with the rules of origin is established.

Protest Rights

Importers or other authorized parties may file a protest to contest a denial of preferential tariff treatment of a claim made at entry, or the denial of a post-importation claim pursuant to 19 USC 1520(d), pursuant to 19 USC 1514 within 180 days of liquidation. If approved, the goods will be eligible for preferential treatment and CBP will refund the duties; MPF will also be refunded for claims that were made at the time of entry. If a protest relates to the analysis of the Department of Labor relating to high-wage components of the labor value content requirements of a covered vehicle, a protestant may not request accelerated disposition of the protest.

Questions regarding this guidance can be directed to Maya Kamar, Director, Textiles and Trade Agreements Division at 202 945 7228 or email FTA@CBP.DHS.GOV.

Questions regarding the automotive certification submission process for LVC certification, Steel certification, and Aluminum certification can be directed to the USMCA Center email at USMCA@CBP .DHS.GOV .


APPENDIX II – Certifications Minimum Data Elements & Motor Vehicle Averaging Election Data Elements

USMCA Certifications Data Elements

The USMCA certifications include the following four types of certifications:

  • Certification of origin for all commodities– See Annex A for the required minimum data elements;

  • Labor Value Content Certification for passenger vehicles, light trucks, and heavy trucks – See Annex B for the required minimum data elements;

  • Steel Certification for passenger vehicles, light trucks, and heavy trucks – See Annex C for the requirement minimum data elements; and

  • Aluminum Certification for passenger vehicles, light trucks and heavy trucks – See Annex D for the required minimum data elements.

Motor Vehicle RVC Averaging Election Data Elements

The Motor Vehicle RVC Averaging Election data elements and requirements - See Annex E to this document.

Motor Vehicle LVC Averaging Election Data Elements

The Motor Vehicle LVC Averaging Election data elements and requirements – See Annex F to this document.


ANNEX A – Certification of Origin

A certification of origin that is the basis for a claim for preferential tariff treatment under this Agreement shall include the following elements:

1. Importer, Exporter, or Producer Certification of Origin Indicate whether the certifier is the exporter, producer, or importer in accordance with Article 5.2 (Claims for Preferential Tariff Treatment).

2. Certifier Provide the certifier’s name, title, address (including country), telephone number, and email address.

3. Exporter Provide the exporter’s name, address (including country), e-mail address, and telephone number if different from the certifier. This information is not required if the producer is completing the certification of origin and does not know the identity of the exporter. The address of the exporter shall be the place of export of the good in a Party’s territory.

4. Producer Provide the producer’s name, address (including country), e-mail address, and telephone number, if different from the certifier or exporter or, if there are multiple producers, state “Various” or provide a list of producers. A person who wishes for this information to remain confidential may state “Available upon request by the importing authorities.” The address of a producer shall be the place of production of the good in a Party’s territory.

5. Importer Provide, if known, the importer’s name, address, e-mail address, and telephone number. The address of the importer shall be in a Party’s territory.

6. Description and HS Tariff Classification of the Good

a)  Provide a description of the good and the HS tariff classification of the good to the 6-digit level. The description should be sufficient to relate it to the good covered by the certification; and


b)  If the certification of origin covers a single shipment of a good, indicate, if known,the invoice number related to the exportation.


7. Origin Criteria

Specify the origin criteria under which the good qualifies, as set out in Article 4.2 (Originating Goods).

8. Blanket Period Include the period if the certification covers multiple shipments of identical goods for a specified period of up to 12 months, as set out in Article 5.2 - Claims for Preferential Tariff Treatment.

9. Authorized Signature and Date The legal name, address, telephone, and email address (if any) of the responsible official or authorized agent of the importer, exporter, or producer signing the certification (if different from the certifier’s name, title, address (including country), telephone number, and e-mail address).

The origin certification must include the following statement:

I certify that the goods described in this document qualify as originating and the information contained in this document is true and accurate. I assume responsibility for proving such representations and agree to maintain and present upon request or to make available during a verification visit, documentation necessary to support this certification.


ANNEX B – Labor Value Content Certification

In order for a covered vehicle to be eligible for preferential tariff treatment under the USMCA, the producer must certify to CBP that it complies with the Labor Value Content (“LVC”) requirements of the Appendix to Annex 4-B (“the automotive appendix”) of the USMCA. The producer must submit the information described below to CBP to certify that it complies with high-wage components of the LVC requirements.

Information to Submit for Certification

(a) To satisfy its certification obligation under section202A(c) of the USMCA Implementation Act pertaining to the high-wage components of the labor value content requirements, a producer of the covered vehicle (as defined in these instructions) must submit the following information in its certification relating to the high-wage components of the labor value content requirement.

(1)  The certifying vehicle producer’s name, corporate address, Federal Employer Identification Number or alternative unique identification number, such as a Business Number (BN) issued by the Canada Revenue Agency, Registro Federal de Contribuyentes (RFC) number issued by Mexico’s Tax Administration Service (SAT), Legal Entity Identifier (LEI) number issued by the Global Legal Entity Identifier Foundation (GLEIF), or an identification number issued to the person or enterprise by CBP, and a point of contact for the certifying vehicle producer.


(2)  The vehicle class, model line, and/or other category indicating the motor vehicles covered by the certification.


(3)  The time period the producer of the covered vehicle is using for its LVC calculations. For purposes of calculating the LVC, a producer of the covered vehicle may use any one of the time periods used for calculating the average hourly base wage rate, as described in Part VI of the Uniform Regulations (Appendix to 19 CFR 182).


(4)  The name, address, and Federal Employer Identification Number or alternative unique identification number, such as a Business Number (BN) issued by the Canada Revenue Agency, Registro Federal de Contribuyentes (RFC) number issued by Mexico’s Tax Administration Service (SAT), Legal Entity Identifier (LEI) number issued by the Global Legal EntityIdentifier Foundation (GLEIF), or an identification number issued to the person or enterprise by CBP, for each plant or facility the producer of the covered vehicle is relying on to meet the high-wage material and manufacturing expenditures component of the LVC requirements.


(5)  A statement that the average hourly base wage rate, calculated consistent with the method provided in Part VI of the Uniform Regulations (Appendix to 19 CFR 182), meets or exceeds US$16 per hour for each plant or facility identified in subsection (a)(4).


(6)  If applicable, a statement that the producer is using high-wage transportation or related costs to meet the high-wage material and manufacturing expenditures component. If the producer is using high-wage transportation or related costs, the producer must identify the company name, address, and Federal Employer Identification Number or alternative unique identification number, such as a Business Number (BN) issued by the Canada Revenue Agency, Registro Federal de Contribuyentes (RFC) number issued by Mexico’s Tax Administration Service (SAT), Legal Entity Identifier (LEI) number issued by the Global Legal Entity Identifier Foundation (GLEIF), or an identification number issued to the person or enterprise by CBP, for each company the producer used to calculate its high-wage transportation or related costs.


(7)  If applicable, a statement that the producer is using the high-wage technology expenditures credit to meet the LVC requirements. If the producer is using the high-wage technology expenditures credit, a producer must identify the percentage the producer is claiming as a credit towards the total LVC requirement.


(8)  If applicable, a statement that the producer is using the high-wage assembly expenditures credit to meet the LVC requirements. If the producer is using the high-wage assembly expenditures credit, the producer must identify the following:

(i)  The name, address, and Federal Employer Identification Number (for U.S. plants) or alternative unique identification number, such as a Business Number (BN) issued by the Canada Revenue Agency, Registro Federal de Contribuyentes (RFC) number issued by Mexico’s Tax Administration Service (SAT), Legal Entity Identifier (LEI) number issued by the Global Legal Entity Identifier Foundation (GLEIF), or an identification number issued to the person or enterprise by CBP for the assembly plant the producer used to qualify for the high-wage assembly expenditures credit; and

(ii)  A statement that the average hourly base wage rate, calculated consistent with the method provided in Part VI of the Uniform Regulations (Appendix to 19 CFR 182), meets or exceeds US$16 per hour for such assembly plants.


(b) To be eligible for preferential tariff treatment immediately upon the USMCA entering into force, producers of covered vehicles must meet the high-wage components of the labor value content requirements set forth in article 7 of the automotive appendix of the USMCA or, if the producer is subject to the alternative staging regime, under Articles 7 and 8 of that appendix, on the date the USMCA enters into force. A producer's initial certification relating to the high-wage components of the labor value content requirement, containing the information described in subsection (a), shall be filed with CBP by December 31, 2020.

(c) Producers of covered vehicles must ensure that records are kept of information to support the calculations submitted under subsections (a)(5), (a)(7), and (a)(8)(ii). Producers must be able to provide records upon request but the records may be physically maintained by a supplier or contractor. Records will be accepted directly from a supplier or contractor where, for example, the producer and supplier or contractor have contracted for such an approach.

(d) The requirements in this section apply to all producers of covered vehicles during the alternative staging regime period and after the alternative stage regime period ends. For purposes of meeting these requirements:

(a)  TheU.S.DepartmentofLabor,inconsultationwithCBP,shallensurethatthecertificationofa producer does not contain omissions or errors before the certification is considered properly filed; and

(b)  a calculation based on a producer's preceding fiscal or calendar year is valid for the producer's subsequent fiscal or calendar year, as the case may be, as set forth in Articles 7 and 8 of the automotive appendix.


Further details on LVC Certification review will be published in US Department of Labor rule- making process. For any Labor related questions, please contact:

Whitney Ford Director, Division of Immigration and Farm Labor Wage and Hour U.S. Department of Labor 200 Constitution Avenue, NW, Room S-3516 Washington, DC 20210 (202) 693-0406


ANNEX C – Steel Certification

In order for a covered vehicle to be eligible for preferential tariff treatment under the USMCA, the producer must certify to CBP that it complies with the Steel (“S&A”) requirements of the automotive appendix.

A covered vehicle shall be eligible for preferential tariff treatment only if the producer of the covered vehicle:

(i)  provides a certification to CBP that the production of covered vehicles by the producer meets the steel purchase requirements set forth in Article 6 of the automotive appendix or, if the producer is subject to the alternative staging regime, Articles 6 and 8 of that appendix; and


(ii)  has information on record to support the calculations relied on for the certification.


For purposes of meeting these requirements:

(i) CBP shall ensure that the certification of a producer does not contain omissions or errors before the certification is considered properly filed; and

(ii) a calculation based on a producer’s preceding fiscal or calendar year is valid for the producer’s subsequent fiscal or calendar year, as the case may be, as set forth in Articles 6 and 8 of the automotive appendix.

Any vehicle producer whose good is the subject of a claim for preferential tariff treatment under the USMCA, must keep records and supporting documents related to the labor value content, steel purchasing, and aluminum purchasing requirements.

The vehicle producer must retain these records for a period of five years and render them for examination and inspection upon request.

When the filer transmits the SPI “S” to indicate a USMCA claim, the filer is certifying the goods comply with all RoO and recordkeeping requirements including all applicable certification requirements – Origin certification, LVC certification, steel certification, and aluminum certifications. The required data elements for the Steel certification are the following:

  • Producer - the producer’s name, address (including country), e-mail address, and telephone number.

  • Certifier - the certifier’s name, title, address (including country), telephone number, and email address.

  • Producer’s Purchase of Steel - the calculation used to determine that the producer has complied with the steel purchasing requirement in GN 11(k)(v). The calculation should include the total value of the vehicle producer’s purchases at the corporate level of steel listed in Table S of the Appendix to 19 CFR part 182 in the territories of one or more of the USMCA countries, the total value of those purchases that qualify as originating goods, and the resulting percentage.

  • Calculation Periods - the period of time over which the purchases are made in the calculations above (i.e., over the previous fiscal year, over the previous calendar year, over the quarter or month to date in which the vehicle is exported, over the fiscal year to date in which the vehicle is exported, or over the calendar year to date in which the vehicle is exported.)

  • Authorized Signature and Date - the certification must be signed and dated by the certifier and

  • Certifying Statement – include following certifying statement: I certify that, over the relevant period indicated in this document, the producer has satisfied the steel purchase requirement as set out in GN 11(k)(v). The information in this document is true and accurate, and I assume responsibility for proving such representations and agree to maintain and present upon request or to make available during a verification visit, documentation necessary to support this certification.


ANNEX D – Aluminum Certification

In order for a covered vehicle to be eligible for preferential tariff treatment under the USMCA, the producer must certify to CBP that it complies with the Aluminum requirements of the automotive appendix.

A covered vehicle shall be eligible for preferential tariff treatment only if the producer of the covered vehicle:

(i) provides a certification to CBP that the production of covered vehicles by the producer meets the aluminum purchase requirements set forth in Article 6 of the automotive appendix or, if the producer is subject to the alternative staging regime, Articles 6 and 8 of that appendix; and

(ii) has information on record to support the calculations relied on for the certification. For purposes of meeting these requirements:

(iii)CBP shall ensure that the certification of a producer does not contain omissions or errors before the certification is considered properly filed; and

(iv)a calculation based on a producer’s preceding fiscal or calendar year is valid for the producer’s subsequent fiscal or calendar year, as the case may be, as set forth in Articles 6 and 8 of the automotive appendix.

Any vehicle producer, whose good is the subject of a claim for preferential tariff treatment under the USMCA, must keep records and supporting documents related to the labor value content, steel purchasing, and aluminum purchasing requirements.

The vehicle producer must retain these records for a period of five years and render them for examination and inspection upon request.

When the filer transmits the SPI “S” to indicate a USMCA claim, the filer is certifying the goods comply with RoO and recordkeeping requirements including all applicable certification requirements – Origin certification, LVC certification, Steel certification, and aluminum certifications. The required data elements for the aluminum certification are the following:

  • Producer - the producer’s name, address (including country), e-mail address, and telephone number.

  • Certifier - the certifier’s name, title, address (including country), telephone number, and email address.

  • Producer’s Purchases of Aluminum - the calculation used to determine that the producer complied with the aluminum-purchasing requirement in GN 11(k)(v). The calculation should include the total value of the vehicle producer’s purchases at the corporate level of aluminum listed in Table S of the Appendix to 19 CFR part 182 in the territories of one or more of the USMCA countries, the total value of those purchases that qualify as originating goods, and the resulting percentage.

  • Calculation Periods - the period of time over which the purchases are made in the calculations above (i.e., over the previous fiscal year, over the previous calendar year, over the quarter or month to date in which the vehicle is exported, over the fiscal year to date in which the vehicle is exported, over the calendar year to date in which the vehicle is exported, or any over time period permitted by Part VI of the Appendix to 19 CFR part 182.)

  • Authorized Signature and Date - the certification must be signed and dated by the certifier and

  • Certifying Statement – include following certifying statement: I certify that, over the relevant period indicated in this document, the producer has satisfied the steel and aluminum purchase requirement as set out in GN 11(k)(v). The information in this document is true and accurate, and I assume responsibility for proving such representations and agree to maintain and present upon request or to make available during a verification visit, documentation necessary to support this certification.


ANNEX E – Motor Vehicle RVC Averaging Election

The purpose of the Motor Vehicle RVC Averaging Election (hereby referred to as “RVC Averaging Election”) is to obtain from a producer of passenger vehicles, light trucks, or heavy trucks an election to average its regional value content (RVC) calculations of such vehicles in accordance with Part VI of the Appendix to 19 CFR Part 182 (Regulations).

The RVC Averaging Election must be completed with respect to each category that is chosen by the producer of a motor vehicle set out in section 16 of the Regulations (Averaging for Passenger Vehicles, Light Trucks and Heavy Trucks). The RVC Averaging Election should be submitted to CBP in the time period provided under subsection 16(6) of the Regulations.

Unlike the motor vehicle averaging election form used under NAFTA (NAFTA Form 447), the required data elements for the Election to Average under the USMCA may be provided in free format.

The required data elements for RVC Averaging Election are the following:

  • Producer Name & Address - the producer’s name, address (including country), e-mail address, and telephone number.

  • Certifier - the certifier’s name, title, address (including country), telephone number, and email address.

  • Averaging Period – the period with respect to which the election is made, including the starting and ending dates.

  • Averaging Category – the averaging category chosen by the producer. The averaging categories are:

o Category A: The same model line of motor vehicles in the same class of vehicles produced in the same plant in the territory of a USMCA country;


o Category B: The same class of motor vehicles produced in the same plant in the territory of a USMCA country; or

o Category C: The same model line or same class of motor vehicles produced in the territory of a USMCA country.

  • Vehicles to be Averaged - the model name, the model line (applies only to category A and C), class of motor vehicle, and tariff classification of the motor vehicles in that category.

  • Location of the Plant – the location(s) of the plant at which the motor vehicles are produced.

  • Basis of Calculation – whether the basis of the calculation is all vehicles in that category chosen by the producer or only those vehicles in that category that are exported to the territory of one or more of the other USMCA countries.

  • Basis of Regional Value Content - the basis of the calculation in determining the estimated regional value content of motor vehicles.

  • Authorized Signature and Date - the authorized officer’s name, title, signature, and date.


ANNEX F – Motor Vehicle LVC Averaging Election

The purpose of the Motor Vehicle LVC Averaging Election (hereby referred to as “LVC Averaging Election”) is to obtain from a producer of passenger vehicles, light trucks, or heavy trucks an election to average its labor value content (LVC) calculations of such vehicles in accordance with Part VI of the Appendix to 19 CFR Part 182 (Regulations).

The LVC Averaging Election must be completed with respect to each category that is chosen by the producer of a motor vehicle set out in section 18 of the Regulations (Labor Value Content). The LVC Averaging Election should be submitted to CBP in the time period provided under subsection 18(16)(g) of the Regulations.

The required data elements for LVC Averaging Election are the following:

  • Producer Name & Address – the producer’s name, address (including country), e-mail address, and telephone number.

  • Certifier – the certifier’s name, title, address (including country), telephone number, and email address.

  • Averaging Period – the period with respect to which the election is made, including the starting and ending dates.

  • Averaging Category – the averaging category chosen by the producer. The averaging categories are:

o Category A: The same model line of motor vehicles in the same class of vehicles produced in the same plant in the territory of a USMCA country;

o Category B: The same class of motor vehicles produced in the same plant in the territory of a USMCA country; or

o Category C: The same model line or same class of motor vehicles produced in the territory of a USMCA country.

  • Vehicles to be Averaged – the model name, the model line (applies only to category A and C), and class of motor vehicle of the motor vehicles in that category.

  • Location of the Plant – the location(s) of the plant at which the motor vehicles are produced.

  • Basis of Calculation – whether the basis of the calculation is all vehicles in that category chosen by the producer or only those vehicles in that category that are exported to the territory of one or more of the other USMCA countries.

  • Estimated LVC and Net Cost – estimated labor value content and net cost of vehicles in that category with respect to the basis of calculation stated above.

  • Authorized Signature and Date – the authorized officer’s name, title, signature, and date.







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