SDAV Global

North America’s trade rules now renew year by year.

At the first USMCA joint review, on 1 July 2026, the United States did not confirm a further 16-year term. Nothing in the agreement changed; the length of time over which its terms can be assumed did.

The first joint review of the United States–Mexico–Canada Agreement (USMCA) took place on 1 July 2026. The three parties met virtually, as the agreement obliges them to do on the sixth anniversary of entry into force. No provision of the text changed that day, and none has changed since.

In a statement the same day, the Office of the United States Trade Representative (USTR) said that the United States “did not agree to renew the USMCA in its current form” and that, as a result, “the USMCA is not renewed”, while confirming that the agreement remains in force pending resolution of the issues raised. Global Affairs Canada, in its own account, presents the review as “not an expiry date, but rather a scheduled check-in”, and notes that the agreement remains in force until 2036. Practitioner accounts record that both Canada and Mexico confirmed their support for a further 16-year term.

Both readings are accurate. What separates them is not the legal position but the planning horizon.

The clause was designed to force a periodic decision, not to end the agreement

USMCA entered into force on 1 July 2020, replacing the 1994 North American Free Trade Agreement. According to the US Congressional Research Service, it is the first US free trade agreement to contain a review and term extension provision — a clause debated in Congress at the time because a mandatory review might unsettle private investment.

The mechanism sits in Article 34.7. Paragraph 1 states that the agreement “shall terminate 16 years after the date of its entry into force” — that is, on 1 July 2036 — “unless each Party confirms it wishes to continue this Agreement for a new 16-year term”. Paragraph 2 requires the Free Trade Commission to meet on the sixth anniversary to conduct the joint review; each party may submit recommendations at least one month beforehand, and Canada filed its own on 1 June 2026. Paragraph 3 sets the form of the decision: each party “shall confirm, in writing, through its head of government”, and if all three do so the term is automatically extended by a further 16 years, with the next review no later than the end of the following six-year period.

Read together, these paragraphs describe a confirmation procedure, not a renegotiation: what extends the agreement is a written act of three heads of government.

One unconfirmed signature turns a six-year cycle into an annual one

Paragraph 4 governs what happens when confirmation is withheld: if a party does not confirm at a six-year review, “the Commission shall meet to conduct a joint review every year for the remainder of the term”. The same paragraph keeps the door open: at any point between that review and expiry, the parties may extend the term by another 16 years by confirming in writing through their heads of government. The extension is therefore deferred, not forfeited.

Two things follow. First, the joint review is separate from withdrawal, governed by Article 34.6: a party may leave on six months’ written notice, and the agreement continues among the others. Neither withdrawal nor termination was triggered on 1 July. Preferential tariffs, rules of origin, investment protections and dispute settlement all remain fully operative until 1 July 2036. That continuity is confined to the agreement itself: since 2025 the United States has applied Section 232 tariffs to Canadian and Mexican steel, aluminium and automotive imports, with partial exemptions for USMCA-compliant goods, so origin qualification and the duty paid are separate questions.

Second, the review sits inside a domestic process with fixed lead times. The USMCA Implementation Act obliges USTR to publish a Federal Register notice at least 270 days before a joint review and to hold a public hearing — held from 3 to 5 December 2025 — to report the US position on extension to the House Ways and Means and Senate Finance Committees at least 180 days before it, and to engage with Congress after a review at which not all parties confirm.

The substance has moved to bilateral tables with dated rounds

The negotiating work has moved outside the trilateral meeting. On 5 March 2026, USTR Jamieson Greer and Mexico’s Secretary of Economy Marcelo Ebrard announced bilateral discussions scoped around “reducing dependence on imports from outside the region, strengthening rules of origin, and enhancing the security of North American supply chains”. On 27 May the two governments announced three rounds: Mexico City on 28–29 May, Washington on 16–17 June, and Mexico City in the week of 20 July. The second round, held on 15–17 June, covered rules of origin, economic security, agriculture, labour and the environment, together with steel, aluminium and automobiles.

Rules of origin recur in every agenda, and the thresholds are demanding. USMCA requires 75 per cent North American content for vehicles and certain key parts, 70 per cent of a vehicle’s steel and aluminium to originate in North America, and 40 to 45 per cent of North American auto content to be made by workers earning at least US$16 an hour — against 62.5 per cent regional content under NAFTA. The calculation method is itself contested: a dispute settlement panel ruled against the US interpretation in December 2022, USMCA provides no appeal, and the question is unresolved.

European and Swiss exposure runs through operations, not through the treaty

No European company is a party to USMCA, which is why the exposure is easily underestimated. The European Union is Mexico’s second-largest foreign investor after the United States, with an investment stock of €206.6 billion in 2024, and EU–Mexico goods trade reached €86.8 billion in 2025. Much of that manufacturing base exists to serve the North American market under USMCA origin rules, while Europe’s own access to Mexico rests on a separate instrument, the Modernised Global Agreement signed on 22 May 2026.

For Switzerland the structure is the same. More than 400 Swiss companies operate in Mexico, employing over 55,000 people directly, and Switzerland is Mexico’s sixth-largest foreign investor. Swiss access to both markets runs through EFTA agreements — with Mexico since 2001, with Canada since 2009 — not through USMCA. A Swiss group’s USMCA exposure is therefore indirect but concrete: it sits in the Mexican or Canadian subsidiary that ships into the United States, and in the customers whose origin calculations include Swiss components.

A second change compounds this: a decree published in Mexico’s Diario Oficial de la Federación on 29 December 2025, in force since 1 January 2026, raised the general import duty on more than 1,400 tariff lines, with a transitional provision addressed explicitly to imports from countries with which Mexico has no free trade agreement in force. For a supplier shipping into a Mexican plant, preferential origin has stopped being an administrative detail and become a price.

What a company can decide for itself

Little of this is within any single firm’s control. Four things are.

  • Treat origin qualification as a documented position, not an assumption. Recalculate regional value content on current bills of materials and know the margin above the threshold, which is itself the live subject of negotiation.
  • Write duty treatment into contracts. Multi-year customer and supplier agreements should carry review and cost-pass-through clauses keyed to a change in tariff treatment, with a defined trigger rather than a general hardship clause.
  • Keep alternative routes qualified in practice. A second supplier that has never shipped under preference is a name on a list, not an alternative.
  • Give preferential status a maintenance schedule. Classification, origin declarations and retention periods age quietly, and their value is now tested annually rather than once a decade.

The dates that will carry information

Three markers belong in the corporate calendar. The fourth US–Mexico round is due in Washington in September 2026. A joint review is then required on each anniversary, the next on 1 July 2027, and any of them may be the occasion at which three heads of government confirm the extension in writing. Absent that confirmation, the agreement runs to 1 July 2036 and ends there.

USMCA remains the only US free trade agreement built around periodic confirmation of its own existence, and whether that design spreads is not yet knowable. What is already observable is a shift in what companies manage: not the terms written into the agreement, which are unchanged, but the length of time over which they may be assumed.

Newsletter

Stay informed about our activities.

Events, publications and association news — a few times a year, in the language of your choice.