Free Trade Agreements (FTAs) drive competitiveness by allowing goods to cross borders with preferential tariffs. At the heart of these benefits lies the certificate of origin—a seemingly simple document that carries immense technical complexity and legal responsibility. The question is not if customs authorities will verify your product’s origin, but when. An origin audit (or “origin verification process” in technical terms) can be disruptive and costly if you're not prepared. It's not just a bureaucratic requirement; it's an in-depth investigation that tests the integrity of your entire supply chain and compliance processes.
Prodensa has partnered with international trade experts to provide valuable analysis and practical insights into the origin audit process, helping organizations understand the importance of documentation, supplier management, and compliance strategy—especially relevant for those pursuing nearshoring or exploring shelter services in Mexico.
We would like to thank Adrián González, President of Global Alliance Solutions, for his valuable participation and collaboration. For companies pursuing turnkey operations in Mexico, understanding origin rules is a vital step in planning and executing a compliant cost-efficient setup.
Contrary to popular belief, origin audits are not always random. While random selection exists, most verifications are driven by specific risk factors constantly monitored by customs authorities—such as Mexico’s National Customs Agency (ANAM) or the U.S. Customs and Border Protection (CBP)—through sophisticated algorithms and data analysis.
The main triggers include:
Understanding these triggers is the first step to shifting from a reactive stance to a proactive compliance strategy.
Once you receive an official notification—whether it's a detailed questionnaire, a request for information, or notice of an on-site verification—time is of the essence. Success depends not on what you do after receiving the letter, but on the compliance structure you've built beforehand.
Robust preparation is based on the following pillars:
1️⃣ Create an Origin Dossier per product: Don’t wait to be asked. For every part number exported under an FTA, maintain a physical or digital folder with all evidence supporting origin qualification. Include:
2️⃣ Appoint a response team: Identify a project leader (usually the Customs or Compliance Manager) and form a cross-functional team including logistics, purchasing, engineering, finance, and legal if needed.
3️⃣ Conduct periodic self-assessments: Annually simulate an internal audit for high-volume or high-risk products to identify weaknesses before the authorities do.
4️⃣ Know timelines and procedures: Each FTA (e.g., USMCA, EU-Mexico) has different timelines for origin verifications. Typically, you'll have 30–45 days to respond. Understand your rights and request extensions if needed.
5️⃣ Maintain records: Most agreements, including USMCA, require you to keep all origin-related records for at least five years. Poor document management is an automatic audit failure.
Your certificate of origin is only as strong as the weakest link in your supply chain. As the producer or exporter, you are ultimately responsible for the accuracy of the information declared—even if it comes from your suppliers. “My supplier told me it was originating” is not a valid defense.
To protect yourself, implement a rigorous supplier management program:
During an audit, customs authorities may verify your suppliers directly. If your supplier can’t substantiate origin, your own certificate becomes invalid.
Most origin-related penalties stem not from fraud but from avoidable technical errors:
Consequences range from retroactive duty payments with penalties to severe fines or even suspension from import/export registries—effectively shutting down operations.
Once your dossier is complete and your team aligned, your audit response must be strategic: