Overview
This article is current at the time of posting.
The United States-Mexico-Canada Agreement (USMCA), which entered into force on July 1, 2020, is unique among US free trade agreements in that it includes a "sunset clause." Under this provision, the Agreement will expire after 16 years unless the Parties agree to renew it for another 16-year term before that deadline. As part of this mechanism, the USMCA requires the Parties to meet on the sixth anniversary of its entry into force to consider whether to extend the Agreement. That milestone — July 1, 2026 — will mark the anticipated start of the Commission’s joint review process to evaluate renewal.
Under US law, the United States Trade Representative (USTR) is required to solicit public comments on the positions the United States should take in these discussions. A request for comments was published on September 16, 2025, and comments and requests to appear at a hearing, scheduled for November 17, are due November 3, 2025.
Background
Article 34.7 of the USMCA requires the Free Trade Commission (the Commission) —composed of representatives of the US, Mexico, and Canada — to conduct a joint review of the Agreement six years after the Agreement enters into force.
During the joint review, each Party must confirm whether it wishes to extend USMCA and submit recommendations for consideration by the Commission. If the Parties agree to an extension, the USMCA will automatically renew for another 16 years.
If the Parties do not agree to extend USMCA in the 2026 review, the Agreement will terminate in 2036 unless the Parties otherwise agree to renew prior to its automatic expiration. Article 34.7 also requires that if the Parties do not decide to renew the Agreement in 2026, they must meet annually to consider renewal until either all Parties agree to renew or the Agreement expires. Parties may confirm their desire to renew in writing through their respective head of government at any time during the initial sixteen year term. If the Parties decide to renew, then the Parties return to conducting joint reviews every six years.
Next Steps
USTR is soliciting comments or oral testimony on any matter relevant to the July 2026 joint review. USTR is specifically seeking the following information:
- Any aspect of the operation or implementation of the USMCA;
- Any issues of compliance with the Agreement;
- 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;
- 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 US competitiveness, productivity, and technological leadership; and
- 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.
All comments must comply with the following requirements
- Submissions must be in English;
- Requests to appear at the hearing must include a summary of intended testimony;
- Comments may include business confidential information, but it must be clearly marked and the submission must be accompanied by a publicly releasable version of the comments.
Considerations
Although the formal joint review is not scheduled to formally begin until July 2026, recent US trade actions (including tariffs on imports from Canada and Mexico, as well as key sectors such as steel, aluminum, and automotive parts) are likely to influence the process. Rather than focusing solely on USMCA-related matters, the review is expected to serve as a broader forum for addressing a wide range of issues. These discussions may unfold over an extended period, making this initial comment period a valuable opportunity for stakeholders to bring relevant matters to USTR’s attention as the Parties prepare to formally convene next year.
For more information on the USMCA joint review, assistance with submitting a comment or request to testify to USTR, or questions on how any potential trade action may impact your business, please contact a member of Steptoe's Trade Policy practice.
