1. Introduction
The Office of the U.S. Trade Representative (USTR), the Mexican Ministry of Economy, and the Canadian authorities formally launched public consultations in advance of the United States-Mexico-Canada Agreement (USMCA) review, scheduled to begin on July 1st, 2026.
This initial stage is significant for several reasons: first, even though the regional trade relationship has gone into considerable turmoil since President Donald Trump returned to the White House, the fact that Mexico, the United States, and Canada are following the steps provided for in their domestic legislation and are attempting to approach the review in an orderly fashion is indeed encouraging.
Moreover, the significance of these comments lies in how, arguably, they will be used to articulate the position of the three countries in 2026 for example, if the vast majority of the comments point at definitive and absolute failures (real or imaginary) on the USMCA, or if the comments suggest that countries are better off without the agreement, it is not hard to imagine what would the authorities (particularly in the United States) would say and do.
Thirdly, the public comment process is relevant to the extent that it may provide a first glimpse of whether what we will witness in 2026 for the USMCA will be a “review” or a “renegotiation”, as widely speculated.
Beyond semantics, and acknowledging that this is a question open to interpretation, in our view the difference between the former (“review”) and the latter (“renegotiation”) is the level of ambition that the proposals imply, e.g., if the changes proposed in the comment period imply a re-balancing of obligations, or if they demand that benefits are removed, we would be in a “renegotiation” scenario. If, on the other hand, the proposals derived from the comments can be enforced using the current authority of governments through administrative and executive actions, then we will be facing a “review” of the USMCA.
2. US Public Consultation Process
The process opened by USTR is public, and the comments received are available on their website. Almost 2,000 comments were received, with participants including US companies and business organizations, as well as respondents from Mexico, such as the Mexican Business Coordinating Council (CCE), the Mexican Council of International Affairs (COMEXI), and the Mexican Institute for Competitiveness (IMCO), among others. Similarly, Canadian businesses that submitted comments included the Canadian Federation of Independent Business (CFIB), the Canadian American Business Council, and the Business Council of Canada.
Based on these initial comments (as of November 15th, the Mexican and Canadian processes remain open), several key conclusions can be drawn. The comments and documents submitted highlight a fundamental consensus: the USMCA should be maintained as a framework for regional cooperation and economic integration. However, this overall agreement coexists with evident tensions in specific proposals. Most acknowledge current implementation shortcomings and suggest enhancing the practical execution of the treaty without altering its text, which will undoubtedly be a significant challenge.
Moreover, a recurring theme is the need to solidify the North American bloc against Chinese competition, prioritizing regional productive and technological integration. Yet a notable contradiction arises here: while several comments urge Mexico to adopt more restrictive stances toward third countries, these comments coexist with others that ask the US administration to maintain the use of tariffs as a valid enforcement mechanism vis-à-vis Mexico and Canada. This tension must be addressed to ensure the legitimacy of the USMCA remains intact.
3. The Way Forward
As discussed earlier, the comments provide some insight into what stakeholders want from the USMCA review process, but that does not mean the governments will follow suit. Indeed, political priorities, extra-trade issues, and even personal friendships or animosities between the leaders will play a role in the process.
Thus, an educated guess on what the future holds for the USMCA leads to three possible scenarios. In an optimal situation, the three parties would quickly agree to prolong the treaty for another 16 years, thereby minimizing volatility and creating space for North America to focus on the larger issues of its regional agenda. Such an outcome would be the ideal result, but this scenario appears increasingly unlikely.
A feasible scenario would entail a conditional renewal, which shall be accompanied by additional work and technical efforts from all signatories. This would require more commitments, specifically from Mexico and Canada, but would maintain the framework’s continuity with feasible modifications.
Under the current conditions, a likely scenario is that the current US administration deliberately avoids renewing the USMCA, preferring to preserve leverage over Mexico and Canada on issues such as migration, investment, and tariff negotiations. This will keep a sword over Mexico and Canada permanently, and although this is not ideal, if the technical review process continues to operate effectively, the situation can remain manageable. Annual reviews would occur until the initial expiration date in 2036.
An essential element in this scenario is that, if the ambition of the Trump administration is significant – if the process turns into a full-scale renegotiation – it is likely that the administration will need to engage with Congress, either through a new version of the Trade Promotion Authority (TPA) or by moderating its ambition so as not to affect particular interests represented in Congress.
4. Final Considerations
Based on comments received during the US process, we know that there is ample interest among stakeholders in the US, Mexico, and Canada. This is a good sign, but to transform such interest into active participation, a follow-up strategy must be implemented. For a successful and beneficial implementation of the treaty, the three countries will need to find compromises, which will not be easy to reach.
The forthcoming 2026 USMCA review is a crucial juncture for trade relations in North America. The consultation process highlights that, despite rising political discord, the three nations remain committed to a rules-based and collaborative framework. The widespread agreement on maintaining the USMCA underscores its crucial role in regional integration, even as differing perspectives on enforcement and competition with China reveal existing frictions.
Ultimately, it is crucial not to underestimate the significance of the review process. Suppose North America fails to seize this opportunity to lay the foundations of a more competitive and vibrant region. In that case, it may take decades before such a golden opportunity presents itself again.