Shipping into the U.S. from Canada has always required planning, but with the removal of the de minimis exemption and the new 35% IEEPA tariffs announced by the Trump administration, small business owners are facing a lot of mixed information. If you’ve felt confused by what couriers are asking from you - you’re not alone.
In this post, I’ll break down what we’ve learned, what’s causing the confusion, and how to protect your business (and profit margins) when shipping cross-border.
What the Law Actually Says
Under CUSMA, whether your product qualifies for duty-free treatment depends on Rules of Origin in Chapter 4 of the agreement.
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If your product is made in Canada and meets the transformation test (tariff shift, wholly obtained, or RVC), then it qualifies as “originating.”
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To actually claim that status, you must provide a Certificate of Origin (or the required 9 data points) to the broker/CBP.
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Without that certification, even goods that should qualify can be treated as non-originating and subject to tariffs.
In other words: CUSMA is about origin + certification, not just what shows in a tariff table.
Understanding HTS Columns
When you look up your HS code in the U.S. Harmonized Tariff Schedule, you’ll see:
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Column 1 (General): The normal MFN duty rate for WTO members.
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Column 1 (Special): Preferential rates for free-trade partners. If you see “Free (CA, MX),” it means Canada/Mexico goods can enter duty-free if proven with CUSMA certification.
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Column 2: Higher statutory rates for non-NTR countries (Cuba, North Korea).
Here’s the catch: sometimes Column 1 General already says “Free” for everyone, so “CA” won’t appear under Special. That doesn’t mean your goods don’t qualify for duty-free. It just means they were already duty-free under WTO rules.
But under the new IEEPA tariffs, even those goods could be surcharged unless you prove CUSMA origin.
Now let’s take a closer look at how the two preferred couriers — Chit Chats and Stallion Express — are approaching these changes, what each requires from merchants, and the steps they’re offering to help us continue shipping across the border.
Stallion Express
Stallion’s approach requires the merchant to do a Verification Process, where the HTS “Special” column (the so-called S-list) is the deciding factor of whether tariffs/duties are applicable. The Verifcation Process was implemented when tariffs for China-made products were first implemented.
If your HS code doesn’t explicitly show “S” or "S+", they caution that tariffs may apply. They currently do not require a CUSMA Certificate of Origin, and it is unclear if the information submitted is sufficient for their Partnered Brokerage to generate a CUSMA Certification of Origin.
Chit Chats
Chit Chats’ approach requires merchants to complete a CUSMA Certificate of Origin (COO). COO is the actual legal requirement that CBP recognizes when exempting shipments from tariffs. This process was launched Friday, August 29th, and they are estimating a 72 hour turnaround for approval.
While the application for the CUSMA COO does not mention anything about the S-list, Chit Chats has updated their blog for their CUSMA Certification process with "How to Check if Your Item Qualifies".
Why the Confusion?
The problem starts with how couriers are interpreting CUSMA (Canada–U.S.–Mexico Agreement) eligibility.
Stallion Express has created a DDP (Delivery Duties Paid) Verification Process. Merchants provide details like SKU, product dimensions, customs declaration (description, HS code, country of origin), manufacturer information, etc.
Then you submit it for DDP verification and Classification. Each submission has a $0.40 CAD + tax fee. The Verification process is designed to check whether the product appears under a “Special” rate (the so-called S-list) in the U.S. Harmonized Tariff Schedule. If there’s no “S” showing for Canada, Stallion warns that the product may still be subject to tariffs.
It will also provide suggested HS codes based on your product description submitted. The downside is if it doesn't think your submitted HS code is appropriate, you can only select from their recommended list.
If you choose to "reject" these recommendations, you are still on the hook for the $0.40 CAD + tax fee.
Chit Chats, by contrast, has created a CUSMA Certification system. This officially launched on Aug 29th. This process asks merchants to complete a CUSMA Certificate of Origin by asking for 9 data elements - type of certifier, exporter/producer information, SKU, description, Country of Origin, HS codes, etc.
Approval is estimated to take up to 72 hours. Their brokers will then file this with U.S. Customs and Border Protection (CBP) as needed to prove duty-free eligibility.
Chit Chat is not charging a fee to submit this CUSMA COO application on Merchant's behalf, but they are charging a Merchandise Processing Fee (MPF - flat rate of $1.86 CAD) and a Shipment Items Fee ($0.21 per line item in your shipment).
So while both couriers are trying to shield merchants from tariffs, they are approaching it in two very different ways.
Which Approach Should You Go With?
The 35% IEEPA tariffs override Column 1 “Free” rates unless CUSMA origin is certified. Without a certificate, a CBP officer has no obligation to honor the exemption.
Both systems aim to help merchants navigate CUSMA, but based on the requirements from CBP and the 35% IEEPA tariff risk, the approach that includes filing a CUSMA Certificate of Origin gives stronger protection overall.
If you ship with Stallion’s method, you risk duties being applied, even if your goods are technically eligible, because there’s no explicit confirmation that a CUSMA Certificate of Origin is being filed.
If you ship with Chit Chats’ method, you’re submitting the information required to generate a CUSMA Certificate of Origin for exemption, and reducing your risk of surprise charges.
Final Thoughts: What Small Businesses Should Do Now
The tariff landscape is messy, and not every courier is handling it the same way. Here’s what we know:
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CUSMA eligibility is about more than an “S” in the tariff table. Rules of Origin + certification are what matter to CBP.
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Without a CUSMA Certificate of Origin, you’re exposed. Even products that should be duty-free could face the 35% surcharge if challenged.
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Couriers are taking different approaches. Stallion’s verification system may help classify products but doesn’t guarantee certification. Chit Chats’ process requires more paperwork upfront but results in a Certificate of Origin that CBP actually relies on.
For Canadian small business owners, the safest way to protect margins right now is to:
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Identify your HS codes correctly.
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Complete a CUSMA Certificate of Origin (include the 9 required elements).
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Submit it to your courier’s broker so exemptions can be claimed properly.
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Budget for the admin time now, so you don’t get blindsided with 35% tariffs later.
The Bottom Line
Both Stallion and Chit Chats are trying to help merchants through a rapidly changing environment. But based on current CBP requirements, the approach that includes filing a CUSMA Certificate of Origin offers stronger protection.
For small businesses, this isn’t just a paperwork exercise — it’s the difference between a sustainable U.S. shipping strategy and a sudden margin hit. Getting your certificates in order now means you can keep serving U.S. customers confidently, without the fear of surprise charges at the border.
Disclaimer: This article is not endorsed by any courier, company, or government agency. The information shared is based on my own research and personal interpretation of available resources. These interpretations may not always be correct, and the situation is evolving quickly - meaning details can change and may be out of date by the time you read this. Please use this as a starting point, and always do your own research and verify details with official sources before making business decisions. We are not responsible for any actions you take based on the information provided here.
References
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U.S. Customs & Border Protection (CBP) – USMCA/CUSMA FAQs
https://www.cbp.gov/trade/priority-issues/trade-agreements/free-trade-agreements/USMCA/FAQs -
Canada Border Services Agency (CBSA) – CUSMA: Certification of Origin requirements
https://www.cbsa-asfc.gc.ca/services/cusma-aceum/cog-com-eng.html -
Canada Trade Commissioner Service – Guide to CUSMA compliance for Canadian exporters
https://www.tradecommissioner.gc.ca/en/market-industry-info/search-country-region/country/canada-united-states-export/us-tariffs/guide-cusma-compliance.html -
U.S. International Trade Commission (USITC) – Harmonized Tariff Schedule of the United States
https://hts.usitc.gov/ -
Pacific Customs Brokers (PCB USA) – How to fill out Certification of Origin under CUSMA/USMCA/T-MEC
https://www.pcbusa.com/post/how-to-fill-out-certification-of-origin-under-cusma-usmca-t-mec -
Borden Ladner Gervais LLP (BLG) – CUSMA compliance and its relevance to the Canada–U.S. tariff dispute
https://www.blg.com/en/insights/2025/04/cusma-compliance-and-its-relevance-to-the-canada-us-tariff-dispute - Stallion Express Tariff Updates -
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Chit Chats - CUSMA Certification Process
https://support.chitchats.com/en/support/solutions/articles/47001280500-cusma-certification-process