CUSMA rules of origin for small businesses

The rules are less intimidating than they look once you see that there are only a few shapes of rule and that each one asks for a different kind of evidence.

The three shapes of rule

Wholly obtained or produced. The good and everything in it comes from the region. Common for raw or minimally processed goods. Evidence: straightforward sourcing records.

Tariff shift. Non-originating inputs must be transformed enough to change classification in a specified way. Evidence: the classification of each imported input, plus a description of what you do to it.

Regional value content. A minimum share of value must be regional, by a prescribed calculation. Evidence: costs. This is the most record-intensive and the most sensitive to change.

Why final assembly in Canada is not the test

The instinct that "we make it here, so it qualifies" is the most expensive assumption in this area. Assembly may or may not constitute the transformation the rule requires.

Equally, brands sometimes assume imported fabric disqualifies them when the applicable tariff shift is in fact satisfied by what they do. The assumption fails in both directions, which is why the rule text has to be read for the specific heading.

The recordkeeping, in practical terms

Supplier declarations stating the origin of each material, refreshed when you change supplier.

Input classifications, if your rule is a tariff shift.

Costings, if your rule is regional value content, with the method documented.

A written determination per SKU tying it together.

Records retained for the required period, reflecting what was true at the time of each entry.

Where small businesses realistically go wrong

Not in the analysis — it is learnable. In the maintenance. A determination made at launch, never revisited, against a supply chain that changed four times.

And in verification readiness: holding the conclusion but not the evidence. Under verification the conclusion is worth nothing without the records behind it.

If you are not going to maintain it internally, maintain it externally. The cost of either is small compared with duty on qualifying goods, or with an unsupportable claim.