Don't Say I Did Not Warn You

According to the preface of the February 3 edition of the Harmonized Tariff Schedule of the United States:

[T]his edition of the HTS does not contain updated rules of origin for all U.S. free trade agreements; such updates must be proclaimed by the President. The rules of origin for the North American Free Trade Agreement, the U.S.-Australia Free Trade Agreement, the U.S.-Chile Free Trade Agreement, the U.S.-Singapore Free Trade Agreement, and the U.S.-Bahrain Free Trade Agreement have been updated to reflect amendments made by the WCO to the international Harmonized System in 2007 and proclaimed by the President in Proclamation 8097, effective February 3, 2007; no similar updates have been proclaimed for any other free trade agreements. No rules of origin for any existing free trade agreement have been updated to reflect the amendments made by the WCO to the international Harmonized System, effective January 1, 2012, and proclaimed by the President in Proclamation 8771, effective February 3, 2012.

Press reports, meaning International Trade Today, state that Customs and Border Protection expects to be issuing rulings on how the changes impact entries. You have to decide whether you can wait for a ruling. Remember that you can show reasonable care by seeking advice from competent internal resources and outside experts such as counsel experienced with customs and trade issues. Of course, reasonable care is only half the battle, until the rules are up to date, there is always the risk that the you might end up owing duties. Think about whether you can use your purchase orders to try and shift some of that risk.