One of the hurdles facing importers in all industries has been keeping up with the ever-changing free trade agreement rules of origin. This has been especially a challenge for textile and wearing apparel companies as their rules tend to be complex and require deep analysis before making claims under a given free trade agreement.

In the last few days, updates have been published about three different agreements. First, on September 25, 2012, there were technical corrections to the NAFTA rules of origin – see http://www.gpo.gov/fdsys/pkg/FR-2012-09-25/pdf/2012-23499.pdf. These are designed to update the NAFTA rules to incorporate recent Harmonized Tariff changes. Then on the 26th, the CAFTA rules of origin were updated to become effective October 13, 2012, see http://www.gpo.gov/fdsys/pkg/FR-2012-09-26/pdf/2012-23612.pdf. Finally, also on the 26th, the Colombia Trade Promotion Agreement preferential tariff rules were published, see http://www.gpo.gov/fdsys/pkg/FR-2012-09-26/pdf/2012-23604.pdf. All of these revisions require importers to carefully evaluate their current FTA claims and update future claims accordingly. Those who do not learn the hard way how investigations uncover violations.