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USTR opens comments for the first annual USMCA review; farm exporters have until Jan. 12 to weigh in

With the trade pact now under yearly review after the U.S. declined a 16-year extension on July 1, USTR is taking written comments and hearing requests on two dockets. No hearing date has been set.

“At that meeting, the United States did not agree to extend the Agreement for a new 16-year term.” That sentence, in a notice the Office of the U.S. Trade Representative (USTR) published Oct. 5, is how the Federal Register now records the outcome of the July 1 joint review of the United States-Mexico-Canada Agreement (USMCA)[1]. The rest of the notice opens the next round: USTR wants written comments and hearing requests for the 2027 annual joint review by Jan. 12, 2027[1].

For grain, meat, dairy and produce shippers, the stakes are the two biggest export markets U.S. agriculture has. Mexico and Canada were the top two buyers of U.S. farm goods in 2025[4].

What the October notice says

The notice sets out the mechanics of Article 34.7 of the agreement. USMCA entered into force on July 1, 2020, and terminates 16 years later, on July 1, 2036, unless each of the three countries confirms it wants a new 16-year term[1]. The Free Trade Commission, made up of the three governments, met on July 1, 2026, for the first joint review. Because the United States did not confirm, the commission “will meet to conduct a joint review annually” until all three countries agree to extend or the term runs out, whichever comes first[1].

USTR is collecting views under Section 611 of the USMCA Implementation Act[1]. It runs two dockets on its own portal, comments.ustr.gov:

  • USTR-2026-0595 for written comments and, later, post-hearing rebuttals[1].
  • USTR-2026-0596 for requests to appear at the public hearing, which must include a summary of testimony[1].

Both written comments and hearing requests are due at 11:59 p.m. EST on Jan. 12, 2027[1]. Rebuttals are due seven calendar days after the last day of the hearing[1]. The notice gives no hearing date or location. It says those details “will be published to USTR’s website”[1]. Oral remarks are capped at five minutes, and because the hearing is public, testimony should not include business confidential information[1].

USTR asks for comments on five topics: the operation or implementation of the agreement; compliance issues; specific actions USTR should propose ahead of the review; the investment climate in North America; and North American economic security, including cooperation on “non-market policies and practices of other countries”[1]. Small businesses, generally those with fewer than 500 employees, and groups representing them are asked to identify themselves as such[1].

How the 2026 request compares with last year’s

USTR ran the same exercise before the first review. Its Sept. 17, 2025, notice set a Nov. 3, 2025, comment deadline and a Nov. 17, 2025, hearing at the U.S. International Trade Commission in Washington[2]. Countries wishing to recommend action at that review had to do so by June 1, 2026[2].

Most of the comment topics carry over almost word for word. One does not. In 2025, USTR asked for recommendations on actions it should propose “to promote balanced trade, new market access, and alignment on economic security with Mexico and Canada”[2]. The 2026 notice asks for recommended actions to propose ahead of the joint review and stops there, without that clause[1, 2]. The 2025 notice also sought views on the North American Competitiveness Committee, which the new notice drops from its list[1, 2]. The October notice does not explain either change.

In the field: which commodities ride on Mexico and Canada

The U.S. exported $171 billion in agricultural goods in 2025, according to USDA’s Economic Research Service (ERS), and 56 percent went to the top five markets: Mexico, Canada, the European Union, Japan and South Korea[4]. That share was down from 62 percent in 2024[4].

Corn, soybeans, pork, poultry and dairy. Mexico is the largest U.S. agricultural trading partner, and exports there grew 1 percent in 2025[4]. The top products shipped to Mexico were corn, dairy products, pork and pork products, soybeans, and poultry meat and products[4]. That list puts corn, soybean, hog, poultry and dairy producers closest to any change on the Mexican side.

Specialty crops, bakery goods and ethanol. Canada was the second-largest market, and exports there fell 4 percent to $28.2 billion[4]. The leading U.S. exports to Canada were bakery goods, fresh vegetables, fresh fruits, ethanol and food preparations[4]. Fruit Growers News reported that the July decision brought no immediate change to tariff treatment or market access for fruit and vegetable growers, but that future talks could take up market access and rules of origin[7].

Dairy. “USMCA is very important to U.S. dairy producers, as over forty percent of our exports ended up in Mexico and Canada last year,” Michael Lichte of Dairy Farmers of America told the House Agriculture Committee at a June hearing titled “Agricultural Perspectives on the Future of the USMCA”[6]. He asked for targeted fixes on dairy issues in the Canadian market and for full access to Mexico, “including for common cheese names like ‘feta’”[6].

Inputs. The National Council of Farmer Cooperatives (NCFC) puts Mexico and Canada at roughly $60 billion, more than a third of U.S. food and agricultural exports[5]. The co-op group also points to the inbound side of the trade: duty-free farm products brought in for further processing, and inputs “such as energy, fertilizer and packaging materials”[5].

The farm groups at the June hearing used similar language. Jamie Beyer, a Minnesota soybean farmer on the American Soybean Association’s executive committee, called the agreement “the gold standard for agricultural trade agreements”[6]. Michael Schumpp of the Meat Institute said maintaining its “stability and market access is critical to farmers, ranchers, processors, and rural communities across the United States”[6].

On the Hill: what Congress gets before the next meeting

The agriculture coalition’s request before July 1 was to renew the agreement with targeted changes. NCFC’s position was that “any adjustments made in the 2026 joint review should target those issues rather than rewriting the agreement”[5]. That did not happen. Administration officials said the United States declined the extension because it wants to deal with trade deficits with Canada and Mexico and with market access issues, including for agricultural products, Fruit Growers News reported[7].

Talks have run on two tracks. USTR and Mexico’s Secretariat of Economy formally launched their review process on March 5, 2026, and by early July had held two full negotiating rounds covering automotive rules of origin, steel and aluminum, economic security, and “conceptual talks on agriculture, labor, and environment,” according to NCFC[5]. A third round was set for the week of July 20 in Mexico City[5]. Canada submitted its formal recommendations on June 1, but bilateral rounds with Canada had not started as of early July[5].

The 2020 implementing law, Pub. L. 116-113, anticipated a failed extension. If any USMCA country does not confirm the extension, USTR must report to the trade committees at least 70 days before each later annual joint review meeting[3]. The report must cover:

  1. any reason a country offered for not agreeing to extend[3];
  2. the progress made toward resolving that country’s concerns[3];
  3. any action USTR intends to raise at the meeting[3]; and
  4. the views of the trade advisory committees set up under section 135 of the Trade Act of 1974[3].

The same section requires USTR to brief the committees within 20 days after each joint review on the positions the countries took and any actions agreed, and to hand over copies of any proposed text it plans to submit to the other two governments if the committees ask[3]. Separately, the law requires USTR to publish a Federal Register notice and hold a public hearing before each joint review, the step the Oct. 5 notice begins[1, 3].

What to watch

  • Jan. 12, 2027: written comments and hearing requests due on dockets USTR-2026-0595 and USTR-2026-0596[1].
  • Hearing date: to be posted on ustr.gov; rebuttals follow within seven days of the hearing’s last day[1].
  • USTR’s report to Congress: due at least 70 days before the 2027 joint review meeting, with the reasons for the impasse and the actions USTR plans to raise[3].

The notice does not say when in 2027 the Free Trade Commission will meet, and the law sets that 70-day report clock from the meeting date[1, 3].