Most companies with Mexico exposure are treating the USMCA as a spectator sport right now. Ebrard says Mexico is “closer every day” to a deal, Washington says little, and the Monday meeting ends with “let’s keep watching.” Meanwhile one piece of the process has a docket number, a deadline and a public record that nobody on your side of the table can write for you.
On July 1, the United States declined to support extending the agreement in its current form. That did not end anything. It switched on the annual review under Article 34.7, and the treaty now runs toward its July 1, 2036 expiry unless all three governments agree otherwise. Preferences, origin certification and dispute settlement keep working today. What changed is that the rules can now be reopened every year, and the file that frames what gets reopened is being built right now.
That file has a front door. The Office of the U.S. Trade Representative (USTR) opened docket USTR-2026-0595 for the 2027 annual review, and comments close January 12 at 11:59 p.m. The notice asks about how the agreement operates, how Mexico and Canada comply, what USTR should propose, North American investment and competitiveness, and economic security against nonmarket policies from third countries. A public hearing is coming; the date is not set.
Here is how we would sort the noise for a government affairs lead walking into a quarter-end planning session in Houston, Detroit or Monterrey.
Three signals that decide what you file
The auto record is already being written. The U.S. International Trade Commission held its hearing on automotive rules of origin on October 14, under Investigation No. 332-608, and posthearing briefs are due October 21. Its report to the administration is due July 1, 2027. If your company makes vehicles, parts, batteries or anything that rides inside them, reported testimony so far has centered on electric vehicles and U.S. worker protection. A country-specific content threshold is under discussion and not adopted. Whatever the Commission’s staff absorb this month will shape the number negotiators argue over next summer.
Section 232 is the real price of Mexican access. Ebrard met Jamieson Greer for about an hour in Milwaukee on October 1, on the sidelines of the G20 trade ministerial. The tariffs have not moved: 25% on Mexican vehicles (charged on the non-U.S. content of qualifying ones) and 50% on steel and aluminum. Mexico has put proposals on both sectors on the table and is waiting for an answer. These duties sit outside the USMCA text, which means a clean comment on rules of origin can be undone by a proclamation. File your exposure with both authorities in view, and say so.
Canada is the variable nobody priced. Talks with Ottawa broke off on August 22, hours before a deadline for 50% tariffs on about $20 billion of Canadian goods. Mexico is now the only partner running formal review negotiations with Washington. That helps Mexico’s position and hurts anyone whose supply chain crosses both borders, because an interim deal with one partner can come with terms that complicate the trilateral rules for the other.
The one to ignore
The optimism. Ebrard’s line is sincere and probably accurate about the mood in the room, but it is not a deal. Greer told the Senate Finance Committee in July that he hoped for interim arrangements by year end, with the harder questions on auto content and labor pushed into 2027 and, in his words, “with Congress in the following year”. The U.S. midterms on November 3 narrow the window further. A company that sets its sourcing plan on “a deal soon” has confused tone with text.
There is a fair counter-argument, and it deserves a straight answer. Public comments rarely move a negotiating position; the heavyweight industry associations will file, and one more letter looks like a rounding error. That is true of generic comments. It is not true of specific ones. A filing that names a tariff line, a bill of materials and a dollar figure for what a 10-point change in regional value content costs gives negotiators something they cannot get from a trade association’s average member. Specific exposure is the only kind of comment that gets quoted back.
What to do with the next 12 weeks
Start with the part you control. Pull your own origin file: which products claim USMCA treatment, which inputs come from outside North America, and which of them a stricter rule would disqualify. Then decide whether to file individually, through an association, or both. Individual filings carry specifics; association filings carry weight. Most companies should do the first and make sure the second does not contradict it.
Second, write the Section 232 paragraph now, even though it belongs to a different authority. If your steel, aluminum or vehicle costs move with those duties, the review is where you can show USTR what the tariffs do to a North American supply chain that the agreement is supposed to protect.
Third, build the hearing slot into the calendar. USTR has said it will hold one and has not named a date. When it does, expect a short window to request time to speak.
The dates that matter: October 21, ITC posthearing briefs. November 3, U.S. midterms. January 12, the docket closes. July 1, 2027, the Commission’s auto report is due. Everything before the last of those is a chance to be in the record rather than a reader of it.
Further reading:
- Haynes Boone: USTR opens comment period for USMCA review (docket USTR-2026-0595)
- Greenberg Traurig: USMCA joint review triggers annual reviews but does not alter current trade benefits
- Mexico News Daily: Ebrard, in Milwaukee, strikes optimistic note on USMCA talks
- Latin Times: Mexico-U.S. trade talks move forward, but steel, autos and Canada complicate the deal
- Zeta Tijuana: Sheinbaum confía en extensión del T-MEC