A subtle but critical change occurred when the USMCA dropped the NAFTA marking requirement, only applying the preferential rules in order to originate and qualify for free or reduced duty treatment.  However, for certain products under various processing scenarios such as those involving section 301 China trade remedies or agricultural tariff rate quotas, traders need to remain wary of exceptions to the USMCA country of origin general rules.

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Lenny P. Feldman
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