FTA Summaries, Preference Programs, and the Fine Print That Saves You Money

General Notes in the HTSUS: What They Are and Why They Matter

Most importers flip straight to the tariff code. A few get as far as the chapter notes. But almost nobody starts in the General Notes of the Harmonized Tariff Schedule of the United States (HTSUS), where the real money-saving opportunities live.

Tucked neatly before Chapter 1, the General Notes are ignored by most and understood by even fewer. Which is unfortunate, because they contain the legal ground rules for free trade agreements, preference programs, and duty relief initiatives that could significantly reduce what you owe at the border, if you qualify.

If you’ve never read them, you’re not alone. But you’re probably leaving money on the table.

What Are General Notes?

General Notes are the foundational rules of the HTSUS. They’re U.S.-specific (not part of the international Harmonized System) and updated regularly, sometimes multiple times a year, to reflect changes in trade policy, agreements, and duty preference programs.

They cover everything from:

• Free Trade Agreements like USMCA, KORUS, and CAFTA
• Preference programs like the Generalized System of Preferences (GSP)
• Industry-specific provisions for automotive, civilian aircraft, pharmaceuticals, and more
• Definitions, eligibility requirements, and limitations for special duty treatments

In short: this is where the rules live. If you’re claiming a duty reduction or wondering why you’re not eligible for one, this is where you start.

How They’re Structured

Each General Note is numbered (e.g., General Note 12 covers USMCA), and includes:

• Definitions of qualifying goods
• Regional value content formulas
• Specific rules of origin
• Recordkeeping requirements
• Exceptions and carve-outs

These aren’t summaries or footnotes. They’re binding legal text. CBP uses them. Importers should too.

Why They Matter

Claiming a preferential duty rate under a free trade agreement or a duty suspension program isn’t optional. It’s a legal assertion. And if that assertion is based on a guess, an assumption, or a supplier’s vague reassurance, it’s going to be a problem when CBP asks for documentation.

We’ve seen importers:

• Claim USMCA benefits for goods assembled in Mexico using Chinese inputs, without realizing they fail the regional value content test
• Assume their product qualified under GSP, only to learn it was excluded in the latest revision
• Miss industry-specific carve-outs that would’ve saved thousands in duties simply because they didn’t know General Notes existed

In each case, the answer was in the General Notes. So was the savings.

Updated Often. Skimmed Rarely.

Unlike the rest of the HTSUS, General Notes are updated frequently, often in response to trade negotiations, legislation, or executive actions. If you’re relying on old copies, outdated assumptions, or recycled classifications, there’s a good chance something’s changed.

Especially now. 

With trade policy evolving and tariff enforcement tightening, eligibility rules are shifting faster than many importers can track. General Notes are how you keep up.

Start With the Fine Print

Before you assign a tariff code, claim a duty-free preference, or certify a shipment as USMCA-eligible, there’s one place you should always begin: the General Notes. Not the product description. Not a broker’s shortcut. And definitely not a third-hand summary in a slide deck from 2019. The actual Notes.

Why? Because this is where the U.S. government defines the rules: what qualifies, what doesn’t, and what exceptions apply. The General Notes spell out the conditions you have to meet before you can legally claim a reduced or zero duty rate. They include formulas for calculating regional value content, define what “originating” actually means under each FTA, and specify documentation and recordkeeping requirements that must be met to support your claim.

And here’s the catch: CBP will assume you’ve read them.

If you haven’t, and something goes wrong, “I didn’t know” isn’t a defense. It’s a red flag.

They may not be thrilling, but the General Notes are the difference between a compliant entry and a costly correction. If you want to claim the benefits, you need to follow the rules. And the rules start here.

Need Help Making Sense of It All?

O’Meara & Associates works with companies to navigate trade agreements, validate eligibility, and ensure classification decisions are backed by the right documentation. If your supply chain has shifted, or your tariff strategy hasn’t been reviewed in a while, we can help you uncover the savings and avoid the slip-ups buried in the fine print.
Contact O’Meara & Associates before your next entry goes under the microscope.