For only the third time in more than 30 years, the public is invited to weigh in on the direction and objectives of North American trade policy. The United States Trade Representative has launched a formal consultation period, in advance of the 2026 joint review of the United States-Mexico-Canada Agreement.

By Suzanne Garner, principal at Truss Faber

For only the third time in more than 30 years, the public is invited to weigh in on the direction and objectives of North American trade policy. The United States Trade Representative (USTR) has launched a formal consultation period, in advance of the 2026 joint review of the United States-Mexico-Canada Agreement (USMCA)—a trilateral stock-take mandated by the Article 34.7 “sunset clause.” The governments will decide whether to extend, change, or terminate the Agreement. Feedback is due by November 3, 2025, and will inform USTR’s negotiating positions.

Washington stakeholders have valuable input should not miss this chance. The comment period is an opportunity for smaller and specialized businesses and trade associations to bring their views and concerns directly to USTR negotiators. Join Suzanne for a virtual Q&A session hosted by CAMPS - Center for Advanced Manufacturing Puget Sound on Wednesday, October 29 at 11 am to learn more about how to participate.

USTR has solicited public input on big-picture negotiating objectives for North America only twice in recent history: in 1991, in the lead-up to negotiating the North American Free Trade Agreement (NAFTA), and in 2017, in the lead-up to renegotiating the NAFTA to form the USMCA, which took effect in 2020.  

Observers suspect the upcoming review could evolve from a technical assessment into a high-stakes renegotiation, given the political attention on trade policy and tariffs in particular. Trade policy is a top priority for the current U.S. administration and, already, the United States has increased tariffs on steel, aluminum, copper, autos, lumber, timber, wood products, and more. These moves have intensified bilateral negotiations and sparked questions about what may come from the trilateral USMCA Joint review.

The Stakes for Washington State

For Washington State—a hub of international commerce, manufacturing, construction, technology, and agriculture—the outcomes of the upcoming review could shape the economic landscape for decades to come.

Washington’s economy drives and relies on North American trade. Mexico and Canada are Washington’s top export destinations after China. In 2024, Washington exported $57.8 billion in goods globally, accounting for 7.2% of the state’s GDP and ranking as the ninth-largest state exporter. In 2023, nearly 90% of the 11,202 companies that exported from Washington were small and medium-sized enterprises (fewer than 500 employees), generating over a quarter of Washington’s total exported goods that year.

In recent years, exports from Washington supported an estimated 160,000 jobs. Notably, in 2024, manufactured products made up $40.7 billion of exports and, in recent estimates, supported135,000 jobs. Washington’s largest manufacturing export categories are equipment, food products, computers and electronics, petroleum and coal products, and non-electrical machinery.

On the import side, in 2024, Washington imported $18 billion in goods from Canada and $11 billion from Mexico, accounting for nearly half of the state’s total imports.

Impact on Washington’s Manufacturing and Construction Sectors

Manufacturing

Washington’s manufacturing sector—especially aerospace, electronics, and industrial machinery—relies on NorthAmerican supply chains. The 2026 review will address policies directly affecting manufacturing, such as:

  • Rules of Origin (ROOs): The USMCA applies preferential tariff treatment to goods originating from member states. ROOs refer to the percentage of “regional content” a product must contain to qualify for the treatment. Content thresholds will likely be examined, and changes would affect supply chains and compliance costs.
  • Tariffs: Fluctuations and uncertainty are already affecting input costs and planning. The review is an opportunity to lock tariff deals in place, and stakeholders can use the comment period to provide negotiators with specific information about business impacts to inform their decisions.
  • Critical Minerals: Washington’s clean-energy and advanced manufacturing sectors rely on imported critical minerals, such as lithium, copper, and rare earth elements. Negotiations could be an opportunity to establish more stable regional access.
  • Technical Barriers to Trade (TBTs): Technical regulations(e.g., product specifications, performance requirements, and conformity assessments) are often overshadowed by a focus on tariffs, but the impacts on trade are significant. For example, exporters of clean energy technology often have to comply with differing technical specifications and certifications, which can be costly. TBT rules are actively negotiated by trade and technical specialists. Small- and medium-sized companies—often the most affected—have a chance to inform the debates.

Construction

Washington’s construction industry also has a stake in the review:

  • Material Costs: Tariffs and regional content thresholds for construction materials such as concrete, cement, steel, aluminum, and copper directly impact costs for infrastructure and housing projects.
  • Government Procurement: The USMCA sets rules for businesses to bid on public projects in another member state, with more limited access at sub-federal levels. The review could revisit these commitments and could loosen or tighten market access.
  • Investment: Changes or uncertainty around trade policy could affect investment in large-scale construction projects, especially those tied to manufacturing or logistics infrastructure. Input can inform officials about the specific impacts of the policy and regulatory climate.

Manufacturing and construction businesses in Washington State have an opportunity to help shape the future of North American trade policy. Sharing your company’s experiences, perspective, challenges, and priorities can have a meaningful impact.

How to Participate: Public Comments and Hearing

To view the Federal RegisterNotice (FRN), visit here.To submit a comment, access the public docket or request to participate in the hearing, visit here.

November 3, 2025, is the deadline to submit comments and request to appear at the public hearing, held in Washington, D.C., on November 17, 2025.

The FRN encourages small businesses to identify themselves in their submissions so that USTR is aware of issues of particular interest.

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Suzanne Garner is a trade and regulatory attorney at Truss Faber PC, advising businesses on tariffs, trade rules, and compliance. She served as an associate general counsel at the United States Trade Representative for almost ten years, covering NAFTA, trade in services, CFIUS, and U.S.-Canada softwood lumber trade.