AUTHOR: Reynaldo Roman – Senior Director, Regulatory Compliance 

In today’s trade environment, tariffs are reshaping supply chain costs in ways many companies did not anticipate. For importers of human specimens moving from Mexico into the United States, this reality is particularly critical. The United States–Mexico–Canada Agreement (USMCA) offers a clear pathway to reduce, or in many cases, eliminate these additional duties. 

Why This Matters 
Under current U.S. trade measures, including tariffs imposed under the International Emergency Economic Powers Act (IEEPA) and Reciprocal Trade Executive Orders, imports from Mexico are subject to additional duties. 

While certain exemptions exist at the HTSUS level, such as Annex II exclusions, they do not apply in all cases. As a result, not all human specimens are exempt, and many shipments remain subject to an additional 25% duty. 

The USMCA Advantage – How it works: 

1. Originating Status – Shipments must qualify as originating in Mexico under USMCA rules of origin. For human specimens, this means they must be sourced and shipped directly from Mexico. 

2. Certificate of Origin (COO) – A valid USMCA COO is required and must include the minimum data elements outlined in Annex 5 (Origin Procedures) of the Agreement. 

3. Blanket Certification – A COO may cover a single shipment or multiple shipments of the same type for up to 12 months, providing a highly efficient solution for recurring movements. 

4. Importer Responsibility – Importers are accountable for the accuracy of any USMCA claim. U.S. Customs and Border Protection (CBP) may request supporting documentation during an audit, and penalties can apply if the claim cannot be substantiated. 

Key Takeaway 
While HTSUS-based exemptions, such as Annex II, may provide limited relief, they are not comprehensive. USMCA remains the most reliable strategy to mitigate the 25% IEEPA and Reciprocal tariffs, provided the rules of origin are met. For importers regularly moving human specimens from Mexico, establishing a blanket Certificate of Origin is a practical, cost-saving step that ensures compliance across shipments. 

Ensuring service reliability remains our top priority. Marken remains committed to supporting clients in navigating the regulatory and trade landscape.

For more information or further clarification on how these requirements apply to your specific shipments, please contact our team at TradeCompliance@marken.com.