CBP has significantly increased its scrutiny of country-of-origin claims for goods entering from Mexico. This enforcement escalation is driven primarily by concerns about transshipment — the practice of routing Chinese-origin goods through Mexico to avoid Section 301 tariffs and other trade remedies. For legitimate Mexico-origin importers, the increased enforcement means more documentation requests, more origin verifications, and a higher standard of proof for USMCA claims.
The enforcement focus has intensified since 2022. CBP has conducted origin investigations across multiple product categories, including
Section 301-related investigations targeting companies that relocated assembly operations to Mexico after tariffs were imposed on Chinese goods. The agency uses data analytics to identify import patterns consistent with transshipment: sudden increases in import volume from Mexico in product categories where the importer previously sourced from China, combined with minimal value-added in Mexico.
Companies that moved assembly to Mexico to
avoid China tariffs face particular scrutiny. CBP examines whether the manufacturing process in Mexico constitutes substantial transformation or merely minor processing designed to change the country-of-origin marking without changing the product's fundamental character. If CBP determines that the goods are of Chinese origin despite assembly in Mexico, the importer faces retroactive duties at the full Section 301 rate, plus penalties for incorrect country-of-origin declarations.
The practical implication for importers is clear: your documentation must be thorough, your origin claims must be defensible, and your customs broker must understand how CBP evaluates these claims. The
USMCA review process adds another layer of uncertainty, as the agreement's rules of origin may be modified during the mandated six-year review. Having a broker who tracks these developments is not optional — it is essential for anyone importing from Mexico in the current enforcement environment.