How to know if your product is CUSMA compliant

There is a definite method here. It is not quick, but it is finite, and doing it once per product gives you an answer you can defend rather than a belief you can repeat.

Step one: classify the product

Everything depends on this, because rules of origin are written against tariff classifications. Until you have the correct heading and subheading, you cannot find the rule that applies.

This is also where most determinations quietly fail. A product classified under the wrong heading will be assessed against the wrong rule, and may be certified as qualifying when it is not.

Step two: find the applicable rule of origin

Each classification has a specific product rule. Broadly, rules take a few forms:

Wholly obtained or produced. Everything comes from the region. Simplest case.

Tariff shift. Non-originating inputs must be classified in a different heading from the finished good — that is, they must be substantially transformed in a specified way.

Regional value content. A minimum proportion of the good’s value must be regional, calculated by a prescribed method.

Some headings combine these. The rule text is what governs, not a general principle about manufacturing.

Step three: trace your inputs honestly

List the materials in the product and their countries of origin, which means obtaining declarations from suppliers rather than relying on where you placed the order.

If the rule is a tariff shift, you need the classification of each non-originating input. If it is regional value content, you need costs. Either way, supplier declarations are the evidence, and they are the part brands most often lack.

Step four: document the conclusion

Write down the classification, the rule applied, the inputs and their origins, the calculation if there was one, and the conclusion. Attach the supplier declarations.

This file is what a verification asks for. A determination held only as a belief is indistinguishable, under verification, from no determination at all.

Step five: keep it true

Re-determine when you change a supplier, substitute a component, add a variant produced differently, or when input costs move enough to affect a value-content calculation.

Nothing will prompt you to do this, which is why qualification silently decays. Running it as a maintained process rather than a one-time project is the entire difference, and it is what OriginOps does.