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October 2025, question 78

Valuation, Appraisement and Duty Assessment · Rules of origin and trade programs

Cylindrical Can Assembly of 8507.90, HTSUS, is produced in Mexico • The sole non-originating material used in the production of the good is nickel-plated steel of 7212.50, HTSUS from Korea • The production in Mexico results in a substantial transformation • Importer is seeking preferential tariff treatment under the USMCA Based on the information provided, which statement is TRUE?

  1. The Cylindrical Can Assembly may not receive preferential tariff treatment under the USMCA because it contains a non-USMCA originating material.
  2. The Cylindrical Can Assembly is eligible for USMCA preferential tariff treatment because it is substantially transformed in Mexico and now a product of Mexico.
  3. The Cylindrical Can Assembly is not eligible for preferential tariff treatment because it is not produced in the United States.
  4. The Cylindrical Can Assembly meets the applicable USMCA rule of origin.
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CBP's answer: B and D. B: The Cylindrical Can Assembly is eligible for USMCA preferential tariff treatment because it is substantially transformed in Mexico and now a product of Mexico.D: The Cylindrical Can Assembly meets the applicable USMCA rule of origin.

CBP keyed both B and D. General Note 11(b)(iii) lets a good made in a USMCA country from non-originating materials be originating if it meets the applicable rule in subdivision (o). The rule for 8507.90 is a change to subheading 8507.90 from any other heading, and the Korean nickel-plated steel of 7212.50 is a different heading, so D is right. The production in Mexico also substantially transforms the good, so B is right too. A is wrong because non-originating materials are allowed when the rule is met, and C is wrong because Mexico is a USMCA country.

the good is a good produced entirely in the territory of one or more USMCA countries using nonoriginating materials, if the good satisfies all applicable requirements set forth in this note General Note 11
A change to subheading 8507.90 from any other heading, except from tariff items 8548.10.05 or 8548.10.15 General Note 11

Search for: produced entirely in the territory of one or more USMCA countries using nonoriginating materials

CBP's key cites: General Note 11; HTSUS 8507.90

Question and key from CBP's October 2025 exam and answer key. The walk-through is ours; quotes are from the pinned editions in the reference viewer (HTSUS 2026 Basic, 19 CFR 2025 edition).