The 2026 Trade Policy Agenda issued by the Office of the United States Trade Representative (USTR) confirms that the formal review of the United States–Mexico–Canada Agreement (USMCA) will take place in 2026, triggering one of the most significant mechanisms built into the agreement.
This process is already in motion. In March 2026, the United States and Mexico initiated the first round of bilateral discussions aimed at outlining the scope of the review, with a focus on ensuring that the benefits of the agreement remain within the region, reinforcing rules of origin, and strengthening the resilience of North American supply chains.
This is not a routine procedural step. It represents a fundamental reassessment of the region’s economic integration model.
The Review Mechanism: A Critical Decision Point
The USMCA incorporates a distinctive provision (Article 34.7) requiring the three countries to convene in 2026 to determine the future of the agreement:
- Extend the agreement through 2042
- Transition into annual review cycles
- Or allow it to sunset in 2036
Key U.S. Concerns
According to the 2026 Trade Policy Agenda, the United States has highlighted several structural concerns in its trade relationship with Mexico and Canada:
- Persistent and growing trade deficits with both countries since the USMCA entered into force
- Ongoing concerns regarding Mexico’s investment environment
- Insufficient enforcement of labor regulations
Taken together, these concerns suggest that the agreement has not fully corrected underlying structural imbalances within the region.
Emerging Strategic Priorities
The 2026 review is expected to expand beyond traditional trade issues and incorporate broader geopolitical and economic considerations, including:
- Investment flows from companies based in non-market economies within North America
- The impact of global industrial overcapacity on regional industries
- The need to further strengthen rules of origin in strategic sectors
In practical terms, this reflects a shift toward tighter control over production processes, origin verification, and compliance across supply chains.
Review or Renegotiation?
Although formally characterized as a review, current conditions indicate that the process could evolve into a more comprehensive renegotiation.
The United States is likely to rely on tariffs and other trade instruments as leverage to secure structural adjustments, particularly in areas such as:
- Rules of origin
- Labor compliance
- Energy sector access
- Domestic content requirements
Given the absence of a clearly defined procedural framework, the outcome will largely depend on political dynamics and negotiation strategies among the three countries.
Negotiation Dynamics
The review process will be influenced by internal and external political factors:
- In the United States, electoral considerations and industrial policy objectives.
- In Mexico, the process is being centrally coordinated, with targeted consultations involving key industries and business organizations, including AMCHAM
- In Canada, there is a clear effort to align positions with Mexico in order to enhance regional negotiating leverage
Implications for Businesses
The USMCA review will have direct implications for companies operating across North America:
- Expanded requirements for origin verification and compliance audits
- Increased pressure to regionalize sourcing strategies
- Stronger regulatory obligations related to labor and environmental standards
Access to the benefits of the agreement will increasingly depend on a company’s ability to demonstrate verifiable compliance.
Conclusion
Against this backdrop, it is essential for companies to proactively evaluate how potential changes to the agreement could impact their operations, supply chains, and market access.
At JA Del Río, our Foreign Trade and Trade Policy team supports companies in assessing these risks, identifying areas of exposure, and developing strategies to adapt to potential changes in the USMCA framework, based on their specific operational models.
