The Office of the US Trade Representative opened public comments on Oct. 2 for the 2027 joint review of the US-Mexico-Canada Agreement. Comments and requests to testify are due Jan. 12, 2027, at 11:59 p.m. EST, under dockets USTR-2026-0595 and USTR-2026-0596. A hearing date has not been set.
A 2027 review exists only because of what happened at the 2026 one. On July 1, the United States declined to confirm a 16-year extension of the pact. That did not end USMCA, but it moved North American trade onto a yearly cycle of reviews, at the same time as Washington and Ottawa are in an open tariff fight.
1. What “not renewed” means
Article 34.7 of USMCA requires a joint review on the sixth anniversary of entry into force. If all three governments confirm they want to continue, the agreement’s term extends for another 16 years. If any one does not, the parties hold annual joint reviews for the rest of the term, and can still agree to extend at any of them. Absent an extension, the agreement ends on July 1, 2036.
The United States did not agree to renew the USMCA in its current form. As a result, the USMCA is not renewed. The United States will continue to engage with Mexico and Canada to address the Agreement’s shortcomings and our trade deficits with these countries. However, the Agreement remains in force pending resolution of these issues or until the Agreement’s termination.
EXCERPT · Statement of Ambassador Jamieson Greer on the USMCA Joint Review, USTR, July 1, 2026
Practically, preferential tariffs and rules of origin still apply. What changed is leverage. Every July, the extension question comes back, and the US can use it to press for concessions on autos, dairy, steel or China-related transshipment without formally withdrawing.
2. Canada: the Section 338 escalation
With Canada, the friction has moved well beyond review talks. On July 20, the President signed three proclamations under Section 338 of the Tariff Act of 1930, a law no president had used before, imposing 50% duties on certain Canadian dairy products, alcoholic beverages and motor vehicles. The dairy proclamation cites Canada’s allocation of dairy tariff-rate quotas, which it says excludes US retailers while EU retailers get access under the EU-Canada trade agreement. White & Case estimates the three proclamations covered about $20 billion a year of US imports from Canada, roughly 5% of the total. That is narrow by value but aimed squarely at politically sensitive sectors on both sides of the border.
I find that it is necessary and appropriate and in the public interest to impose an additional ad valorem duty of 50 percent on certain products of Canada, as identified in Annex II to this proclamation…
EXCERPT · Proclamation on Canadian dairy, July 20, 2026
After a three-day suspension, the duties took effect Aug. 22. Canada answered with retaliatory tariffs of 15% to 50% from Sept. 8. The same day, the White House issued five more proclamations: two revising product lists from Sept. 15 and three imposing outright import bans on certain Canadian alcohol, dairy, molasses, non-alcoholic beer and motorcycle products from Sept. 29.
Two features make these duties unusual. CRS notes they apply with “no exemptions for USMCA” and stack on top of any Section 232 tariffs. And a ban, unlike a tariff, cannot be priced in; goods are simply refused entry.
A ban, unlike a tariff, cannot be priced in; goods are simply refused entry.
3. Mexico: still at the table
Mexico’s track looks different. USTR said in July that it would meet Mexico the week of July 20 for a third round of bilateral talks tied to the review. Mexico has not been hit with Section 338 duties. Under the forced-labor Section 301 tariffs, both Mexico and Canada pay the lower 10% rate, and USMCA-qualifying goods are exempt.
That divergence is the story to follow. One partner is negotiating inside the review process; the other is in a tariff exchange running alongside it. How the US treats each at the July 2027 review will show whether the annual mechanism works as a pressure valve or a standing threat.
4. What to watch
- Jan. 12, 2027: comment and hearing-request deadline for the 2027 joint review (dockets USTR-2026-0595 and -0596).
- Hearing date: to be posted on ustr.gov.
- July 1, 2027: the next joint review, and the next chance for all three parties to confirm an extension.
- Section 338 lists: further product-scope changes, which have so far come with one to three weeks’ notice.
- Ambassador Greer Issues Statement on the USMCA Joint Review — USTR · ustr.gov
- USTR Seeks Public Comment on the 2027 Joint Review of USMCA — USTR · ustr.gov
- USMCA Joint Review: Process and Role of Congress (R48787) — Congressional Research Service · congress.gov
- Imposing Additional Duties to Offset Canadian Discrimination ... With Respect to Dairy — The White House · whitehouse.gov
- Active Presidential Tariff Actions in 2026 (R49481) — Congressional Research Service · everycrsreport.com
- White House Ups the Ante with Section 338 Import Bans Against Canadian Products — Dorsey & Whitney · dorsey.com
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