USMCA Certification Indicator: A, B, C, and D Codes and Fixes

The USMCA certification indicator is the single-digit code on your electronic entry summary that tells U.S. Customs and Border Protection which party signed the certification of origin backing your preferential tariff claim. There are four values: 1 for exporter, 2 for producer, 3 for importer, and 4 for unknown. The code you transmit must match the party who actually signed the certification document sitting in your file, because CBP uses this field to decide who they contact if they verify the claim and who bears responsibility for its accuracy.

Who Can Sign a USMCA Certification of Origin

USMCA Article 5.2 allows three parties to complete a certification of origin: the exporter, the producer, or the importer.¹ That is a change from the NAFTA regime, which limited certification to exporters and producers and required a specific form. Today there is no prescribed format, and the certification can appear on an invoice, a standalone document, or other commercial paperwork, as long as it is not issued in a non-USMCA country.²

Each signer type carries different practical weight. Exporters usually have direct visibility into the supply chain and transaction values. Producers hold the manufacturing data behind tariff shift analysis and regional value content calculations. Importers who certify take on the most exposure, because they are often relying on information passed to them by trading partners rather than firsthand production records. If an importer fails to meet conditions CBP sets, that importer can be barred from self-certifying on future entries.¹

Picking the Right Indicator Code

When you file the entry summary electronically through the Automated Commercial Environment, you transmit one of four indicator values:

Code 1 — the exporter completed the certification.
Code 2 — the producer completed the certification.
Code 3 — the importer completed the certification.
Code 4 — unknown, used when the certifier’s role cannot be determined at the time of filing.

The rule is simple: the code has to match the signature on the certification. If an exporter prepared and signed the document but you transmit Code 3, that discrepancy between your electronic filing and the supporting paperwork can cause CBP to reject the preferential claim or flag the entry for review. Pull the certification before transmitting and confirm the certifier type field on the document itself. Code 4 exists for genuine ambiguity, not as a placeholder to use because you did not check.

You will occasionally see the codes described with letters rather than numbers in older or third-party materials. The four categories are the same regardless of labeling: exporter, producer, importer, unknown.

How the Indicator Fits with the Rest of the Entry

Claiming USMCA treatment happens at the entry summary stage by adding a Special Program Indicator prefix to the Harmonized Tariff Schedule subheading for each qualifying line. Under 19 CFR 182.11, the importer or customs broker places the letters “S” or “S+” before the HTSUS number on CBP Form 7501 or its electronic equivalent.³

The “S” prefix covers the vast majority of USMCA claims. The “S+” prefix is reserved for a narrower set, primarily certain agricultural products and non-originating textile and apparel goods entered under tariff preference level provisions.⁴ Using the wrong prefix can cause ACE to reject the entry or push it into manual review.

When ACE processes the entry, it checks the SPI prefix, the certification indicator, and the product classification for consistency. A mismatch anywhere in that trio can generate an error or route the entry for a closer look. When everything lines up, the preferential duty rate applies, which for many commodities is the difference between zero duty and a rate well into the double digits.

When You Do Not Need a Full Certification

Not every shipment needs a formal certification behind the indicator. CBP waives the certification requirement for commercial imports valued at $2,500 or less, provided the shipment is not part of a series structured to avoid the rules.⁵ Non-commercial imports are exempt regardless of value. Even under the waiver, CBP may still require a written statement that the goods qualify as originating.

Thresholds differ across the three countries. Canada uses CAD $3,300 and Mexico uses USD $1,000, so exporters shipping from the U.S. should confirm the destination country’s threshold before deciding what paperwork to prepare.

What Sits Behind the Indicator

The indicator points CBP to a real document, and that document must contain nine minimum data elements set out in Annex 5-A of the agreement and implemented at 19 CFR 182.12.² Missing any element can lead to denial of preferential treatment and assessment of the full duty rate.

Certifier type — whether the certifier is the exporter, producer, or importer. This is the field your indicator code must match.
Certifier details — name, title, address including country, phone, and email.
Exporter information — name, address, email, and phone if different from the certifier. Not required when a producer is certifying and does not know the exporter’s identity.
Producer information — name, address, email, and phone if different from the certifier or exporter. Multiple producers can be listed individually or noted as “Various.”
Importer information — name, address, email, and phone if known.
Goods description and tariff classification — a description matching the invoice, plus the Harmonized System classification to six or more digits.
Origin criterion — the specific rule the good satisfies, such as a tariff shift, a regional value content threshold, or being wholly obtained in the territory.
Blanket period — if the certification covers multiple shipments of identical goods, the covered period, up to 12 months.¹
Authorized signature and certification statement — the certifier signs, dates, and includes a statement accepting responsibility for accuracy and agreeing to provide supporting documentation during verification.²

Many businesses fold these elements into a standard commercial invoice template. Others use standalone documents. Either works.

If the Code or the Certification Turns Out Wrong

If you find out after filing that the certification was based on inaccurate information, you have to correct the claim promptly, pay any duties owed, and submit a statement to the CBP office where the original claim was filed or through the electronic filing system.³ The obligation to correct is on you, not on CBP to discover the problem.

Both the certifier and the importer must keep records for at least five years from the date of entry. For the certifier, that means documents on the origin of the goods, cost and sourcing information, purchase records, payment documentation, and production records. For the importer, it means the certification of origin plus records tied to the importation, including purchase, cost, value, shipping, and payment documentation.⁶ If you cannot produce records when CBP asks, the agency can retroactively deny the preferential treatment and assess the full duties, plus interest.

False or inaccurate certifications also expose the filer to civil penalties under 19 U.S.C. § 1592, which covers fraud, gross negligence, and negligence.⁷ Fraud penalties can reach the full domestic value of the merchandise. Gross negligence penalties can reach the lesser of the domestic value or four times the duties lost to the government, or up to 40 percent of dutiable value if duties were not affected. Negligence penalties can reach the lesser of the domestic value or two times lost duties, or up to 20 percent of dutiable value if duties were not affected.

There is a meaningful safety valve. If you disclose an error before CBP starts a formal investigation, the fraud penalty drops to 100 percent of the unpaid duties rather than the full domestic value of the goods.⁷ That prior disclosure route is the reason experienced trade compliance teams build regular internal audits into their processes. Catching a mismatched certification indicator or a defective certification before CBP does is the cheapest form of risk management in customs work.

1
Office of the United States Trade Representative. USMCA Chapter 5 – Origin Procedures
2
eCFR. 19 CFR 182.12 – Certification of Origin
3
eCFR. 19 CFR 182.11 – Filing of Claim for Preferential Tariff Treatment Upon Importation
4
U.S. Customs and Border Protection. USMCA Frequently Asked Questions
5
U.S. Customs and Border Protection. USMCA Frequently Asked Questions
6
eCFR. 19 CFR Part 182 – United States-Mexico-Canada Agreement
7
Office of the Law Revision Counsel. 19 USC 1592 – Penalties for Fraud, Gross Negligence, and Negligence