Members and scope
Five major FTAs cover most of world trade outside the EU. One product can qualify under several agreements at once — the practical question is which rule of origin is cheapest to satisfy given your supply chain. The tables below compare members, origin tests, and certification across USMCA, CPTPP, RCEP, ACFTA, and CAFTA-DR.
| FTA | Members | In force | Coverage |
|---|---|---|---|
| USMCA | US, Mexico, Canada | 2020-07-01 | Goods + services + investment + digital trade |
| CPTPP | Japan, Singapore, Vietnam, Australia, New Zealand, Mexico, Canada, Chile, Peru, Malaysia, Brunei, UK | 2018-12-30 (UK 2024) | Goods + services + investment + IP |
| RCEP | CN, JP, KR, AU, NZ + ASEAN-10 (ID, MY, PH, SG, TH, VN, BN, KH, LA, MM) | 2022-01-01 | Goods + limited services + investment |
| ACFTA | China + ASEAN-10 | 2010-01-01 (goods); upgraded 2025 | Goods + investment + services |
| CAFTA-DR | US + Costa Rica, El Salvador, Guatemala, Honduras, Nicaragua, Dominican Republic | 2006–2009 (rolling) | Goods + services + investment |
Rules of origin
| FTA | Wholly obtained | CTC requirement | RVC threshold | Accumulation | De minimis |
|---|---|---|---|---|---|
| USMCA | Yes — Article 4.3 | CTC default per product-specific rule | 60% transaction value / 50% net cost; autos 75% | Full cross-accumulation among 3 parties | 10% |
| CPTPP | Yes — Article 3.3 | CTC by PSR; some lines RVC-only | 40–55% varies by chapter | Full accumulation across all 11+1 members | 10% |
| RCEP | Yes — Article 3.2 | CTC OR RVC (alternative) | 40% | Full accumulation across all 15 members (RCEP's main selling point) | 10% |
| ACFTA | Yes | CTC OR RVC (alternative) | 40% | Bilateral initially; ASEAN-wide under 2025 upgrade | 10% |
| CAFTA-DR | Yes — Article 4.1 | CTC required by PSR | 35% build-up / 45% build-down | Accumulation among parties | 10% |
Certificate of origin
| FTA | Certification type | Issuer | Validity |
|---|---|---|---|
| USMCA | Self-certified (9 data elements, Annex 5-A) | Exporter, producer or importer | Blanket period up to 12 months |
| CPTPP | Self-certified | Exporter, producer or importer | Blanket period up to 12 months |
| RCEP | Issued CO OR approved-exporter self-certification (phase-in) | Authorized chamber/authority or approved exporter | 12 months |
| ACFTA | Form E (issued) | China CCPIT / ASEAN designated authority | Per shipment |
| CAFTA-DR | Self-certified with required data elements | Exporter or producer | Blanket period up to 12 months |
When to choose which
When to choose which
- USMCA — Default agreement for North American trade. Auto rules of origin are the strictest of any modern FTA — 75% regional value content plus a labor value content (LVC) rule requiring a share of production at a minimum wage. Outside autos, the regime is largely a continuation of NAFTA with modernized digital and labor chapters.
- CPTPP — Best when a product needs cross-bloc accumulation — for example, Japanese-made components going into a Mexican export to Vietnam. Full accumulation across all members makes CPTPP the only practical path for multi-country regional supply chains. UK accession in 2024 added a European node to the bloc.
- RCEP — The easiest origin compliance for Asian intra-trade. A flat 40% RVC or CTC alternative, plus full 15-country accumulation, means most regionally-sourced goods qualify with minimal documentation. Use RCEP wherever the destination is an Asia-Pacific member, unless a bilateral FTA (e.g., China–Korea FTA) offers a deeper margin.
- ACFTA — Cheapest path for goods moving between China and ASEAN. The 2025 upgrade adds digital trade, investment, and standards chapters, narrowing the gap with RCEP. For purely China–ASEAN bilateral flows, ACFTA often remains operationally simpler because traders and brokers are familiar with Form E.
- CAFTA-DR — Governs Central American + Dominican Republic trade with the US. The yarn-forward textile rule is the dominant constraint — apparel must be made from yarn produced in a party country to qualify, which routinely disqualifies otherwise compliant garments. Outside textiles, the agreement is straightforward.
Key constraints and gotchas
Key constraints and gotchas
- USMCA — Auto regional value content lifted to 75% (up from NAFTA's 62.5%). Labor Value Content rule requires 40–45% of vehicle value to be made by workers earning at least USD 16/hour — unique to USMCA.
- CPTPP — Yarn-forward textile rule is strict. Limited short-supply list allows non-originating yarns for specific items, but the default is rigorous fabric-and-yarn origin.
- RCEP — Not all members have ratified all chapters; services and investment lag goods. Originating status under RCEP is generous but enforcement maturity varies by customs administration.
- ACFTA — The 2025 upgrade (Version 3.0) adds digital trade and investment chapters and modernizes the rules of origin annexes. Older Form E procedures still dominate paperwork at most ASEAN ports during the phase-in.
- CAFTA-DR — Yarn-forward textile rule originated here and remains the dominant constraint. Cumulation with the US is allowed but not with non-party Asian yarn suppliers, which limits apparel sourcing options.