The goods cleared at the full rate in March because the supplier's certification arrived in June. That does not end the story, but it starts a clock. USMCA lets you claim the preference after the fact. It gives you one year from the date of importation to do it, and the refund does not arrive on its own.
Section 1520(d), the post importation preference provision carried into USMCA, allows an importer to claim preferential treatment after entry within one year of importation, provided the claim includes a written declaration that the goods qualified as originating, a copy of the certification of origin, and the importer numbers and entry details for the lines claimed. CBP's USMCA guidance lays out the same package. It is a statutory claim with a checklist, not a request for discretion.
The one year runs from importation, not from liquidation and not from when the supplier finally sent paperwork. That surprises teams used to the protest clock, which runs from liquidation and lasts 180 days. Two different clocks govern two different remedies, and a claim filed on protest timing for a 1520(d) window that closed months earlier is simply late.
The certification of origin is the centre: it can be completed by the importer, exporter, or producer, it needs the data elements the agreement lists, and it can cover a blanket period of up to 12 months for repeat shipments of identical goods. Alongside it, keep the support that would survive a verification: bill of materials or production records showing how the good meets its rule of origin, whether that is a tariff shift, a regional value content calculation, or both.
CBP can and does verify USMCA claims after the fact, including claims made post importation. A refund received is not an origin finding. If a later verification fails, the duties come back with interest, which is why the claim file should be assembled as if it will be read by someone whose job is to doubt it.
The miss is structural. Entry teams file at the rate the paperwork supports on arrival day, which is correct. Nobody owns the follow up: the supplier certification arriving weeks later lands in an inbox, gets filed with the entry packet, and the one year window closes quietly while everyone assumes the broker is watching it. Brokers watch what they are instructed to watch.
The fix is a tickler with a name on it. Every entry filed at a full rate where USMCA was expected goes on a list with its importation date plus eleven months as the action deadline, owned by a person, reviewed monthly. The list is short for most importers. The refunds sitting on it are real money left in a drawer with a dated lock.
File through your broker in ACE with the declaration and certification attached to the claim as CBP directs, entry by entry, line by line. Partial claims are fine: claim the lines the certification genuinely covers and leave the rest. Stretching a blanket certification across goods it does not describe converts a clean refund into a verification problem.
Track claim status the way you track entries. A filed claim is not a paid claim, and a denied claim, usually for a paperwork defect, can often be corrected inside the window if anyone is watching. The window rewards the organised twice: once for filing, once for fixing.
Keep reading: USMCA claims live or die on the supplier declaration you kept, Post summary corrections and protests: which clock is your entry on.
One year from the date of importation, under the post importation claim provision in 19 USC 1520(d). That clock is different from the protest clock, which runs 180 days from liquidation. A claim that would be timely as a protest can already be late as a 1520(d) claim, so diarise from the import date.
A written declaration that the goods qualified as originating when imported, a copy of the certification of origin, and the entry details identifying the lines claimed. Behind the certification, keep the origin support, bill of materials or regional value content work, because CBP can verify the claim afterwards.
Yes. The certification does not have to predate the entry for a post importation claim; it has to cover the goods and be held when the claim is filed. It can also be a blanket certification covering identical goods for up to 12 months, which suits repeat shipments from the same producer.
The preference is denied and duties are owed, with interest, even if a refund was already paid on the claim. A refund is a processing result, not an origin ruling. That is why the claim file should hold the full origin evidence, assembled to survive a verification, before the claim goes in.