Importance of Origin Traceability for Goods Under CPTPP
Critical circular instructing Mexican customs brokers to conduct strict and detailed origin traceability reviews for all operations requesting CPTPP tariff preferences. Emphasis is placed on verifying certification schemes, documentary consistency, and full compliance with specific rules of origin.
What changes
Establishes the obligation to conduct exhaustive origin traceability reviews for CPTPP preference operations, beyond simple formal verification of the certificate of origin. Customs brokers must verify the applicable certification scheme, documentary consistency, and compliance with specific rules of origin to prevent simulation or triangulation schemes.
Who is impacted
Mexican customs brokers, importers requesting tariff preferences under CPTPP, companies trading with CPTPP member countries (Australia, Brunei, Canada, Chile, Japan, Malaysia, New Zealand, Peru, Singapore, and Vietnam).
Recommended actions
- ›Verify that the origin certification scheme corresponds to those permitted by CPTPP according to the country of origin (competent authority for Malaysia and Vietnam, or certification without pre-established format for other countries)
- ›Review authentication elements according to circulars G-0109/2025 and G-0479/2022 for certificates from Malaysia and Vietnam
- ›Validate that certifications without pre-established format comply with minimum requirements of CPTPP Annex 3-B
- ›Ensure logical and documentary consistency between the certificate/certification of origin and the specified origin criterion
- ›Consult Circular G-0048/2024 for correct specification of rules of origin
- ›Rule out minimal or merely formal transformations that do not confer CPTPP region origin
The Confederation of Customs Brokers Associations of the Mexican Republic (CAAAREM) has issued circular T-0110/2026 with critical status, establishing guidelines to ensure proper granting of tariff preferences under the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP/TIPAT).
The circular identifies that origin review by customs brokers has traditionally focused predominantly on the formal existence of the certificate or certification of origin, without conducting a comprehensive analysis of goods' origin traceability. This practice limits the detection of possible simulation or triangulation schemes that could result in improper application of tariff preferences.
Customs brokers are instructed to verify three fundamental elements: first, that the origin certification scheme corresponds to those permitted by the Treaty, distinguishing between countries that use competent authority (Malaysia and Vietnam) and those that allow certification without pre-established format meeting minimum requirements of Annex 3-B (Mexico, Australia, Brunei, Canada, Chile, Japan, New Zealand, Peru, and Singapore). Second, that logical and documentary consistency exists between the certificate of origin and the specified origin criterion. Third, full compliance with specific rules of origin, ruling out minimal or merely formal transformations.
CAAAREM emphasizes that this exhaustive review should not be understood as an additional burden, but as an essential mechanism for preventing fiscal and legal risks that protects both the importer and customs brokers themselves against potential liabilities arising from improper application of preferential tariff treatment.