USMCA Review Process and Request for Public Comments

Fred Fischer, Senior Vice President

On September 17, 2025, the Office of the U.S. Trade Representative (USTR) published notice in the Federal Register requesting public comments on the operation of the United States-Mexico-Canada Agreement (USMCA) in advance of the USMCA Joint Review on July 1, 2026. USTR is seeking public comments on the operation of the Agreement, including on the operation of the North American Competitiveness Committee (Competitiveness Committee) established therein.

Key Documents and Resources

•  Federal Register Notice, September 17, 2025
• USMCA Text, July 1, 2020
• USMCA Implementation Act, Public Law 116-113

USMCA Review Process

The United States-Mexico-Canada Agreement (USMCA) includes a unique review mechanism outlined in Article 34.7, which mandates a formal evaluation six years after the agreement’s entry into force, which was July 1, 2020. The first joint review is scheduled for July 1, 2026, and will be conducted by the Free Trade Commission composed of representatives from Canada, Mexico, and the United States, and is intended to assess the agreement’s effectiveness and consider any proposed modifications.

During the review, the three parties may agree to extend the agreement for an additional 16 years (until 2042). If the agreement is not renewed in 2026, annual reviews will be held for a period of 10 years. At any point during that cycle, the three parties may still agree to renew the agreement for an additional 16 years. The cycle repeats every six years. If no consensus is reached during the annual reviews, the agreement will expire on July 1, 2036.

Key Dates

•  November 3, 2025: Deadline for submitting written comments and requesting to appear at the public hearing
• November 17, 2025: USTR will hold a public hearing in the main hearing room of the U.S. International Trade Commission, 500 E Street SW, Washington, DC 20436, beginning at 10 a.m. If necessary, the hearing may continue the next business day.
• November 24 or 25, 2025: Deadline for submitting post-hearing briefs and rebuttal comments
• January 3, 2026: USTR report to the U.S. Congress outlining its assessment, recommendations, and position regarding the potential extension of the USMCA
• July 1, 2026: In accordance with Article 34.7 of the Agreement, the USMCA Commission convenes for its first formal review meeting

Request for Public Comments

In advance of the USMCA Review, the USMCA Implementation Act requires USTR to provide an opportunity for the presentation of views regarding the operation of the USMCA. The deadline for submitting comments is November 3, 2025.

• Public Docket to Submit Comments on the USMCA Review 

USTR is inviting comments on any aspect of the operation or implementation of the USMCA, as well as comments on Competitiveness Committee established under Article 26.1 of the USMCA to develop and implement cooperative activities in support of a strong economic environment that incentivizes production in North America, among other purposes.

USTR is specifically seeking comments regarding:

1.  Any issues of compliance with the Agreement.
2. Recommendations for specific actions that USTR should propose ahead of the Joint Review to promote balanced trade, new market access, and alignment on economic security with Mexico and Canada.
3. Factors affecting the investment climate in North America and in the territories of each Party, as well as the effectiveness of the USMCA in promoting investment that strengthens U.S. competitiveness, productivity, and technological leadership.
4. Strategies for strengthening North American economic security and competitiveness, including collaborative work under the Competitiveness Committee, and cooperation on issues related to non-market policies and practices of other countries.

Request to Appear at the Public Hearing

USTR will convene a public hearing on November 17, 2025, at 10:00 a.m. EST, in the Main Hearing Room at the U.S. International Trade Commission, 500 E Street SW, Washington, DC 20436. If necessary, the hearing will continue the next business day. Persons wishing to appear at the hearing must provide written notification of their intention and a summary of the proposed testimony by November 3, 2025.

• Public Docket to Request to Appear at the USMCA Hearing

Next Steps

AGS encourages clients to submit public comments on the operation of the USMCA and on the renewal of the agreement. AGS can assist with reviewing public comments, testimony, and post-hearing rebuttal briefs. We suggest beginning this process as soon as possible. Please reach out to Fred Fischer for questions and assistance regarding the USMCA review.

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