USTR Seeking Comments on USMCA As Part of 6-year Sunset Review in July 2026 (alert sent on 17 September): On Wednesday, 17 September, USTR published an FRN seeking comments within 45 days on the operation of the USMCA for the mandatory six-year review. USTR is inviting comments on:
Aspects of the operation or implementation of the USMC
Issues of compliance with the Agreement
Recommendations for specific actions that USTR should propose ahead of the Joint Review to promote balanced trade, new market access, and alignment on economic security with Mexico and Canada
Factors affecting the investment climate in North America and in the territories of each Party, as well as the effectiveness of the USMCA in promoting investment that strengthens U.S. competitiveness, productivity, and technological leadership
Strategies for strengthening North American economic security and competitiveness, including collaborative work under the Competitiveness Committee, and cooperation on issues related to non-market policies and practices of other countries
The timeline is as follows:
Monday, 3 November: Deadline for submitting written comments, requests to appear at the hearing, and a summary of testimony (by 11:59 p.m. EST 45 days after publication in the Federal Register).
Monday, 17 November: Public hearing at the U.S. International Trade Commission.
Seven days after the last day of the public hearing: Deadline for submission of post-hearing rebuttal comments.
Commerce Seeking Comments on the Expansion of Imports Subject to Section 232 Tariffs: On Wednesday, 17 September, Commerce published an FRN opening a two-week comment period for inclusion requests of steel/aluminum derivative products to expand Section 232 tariff actions. Inclusion requests are scheduled to happen between 15 September 2025 – 29 September 2025. This follows earlier actions which led to additions from Chapter 73 articles of iron and steel and Chapter 76 aluminum. Examples of additions include tube/pipe fittings of iron/steel of 7307, aluminum wire, cables, and bands of 7614, and aluminum cans, boxes, and containers of 7612 and 7613. As the Section 232 steel/aluminum lists expand further, we anticipate PMMI processing and packaging machinery of HS codes 8422 and 8438 could potentially be targeted. There is nothing to indicate that is the case at this time; we will monitor for publication of the expanded list from this FRN and advise if 8422 or 8438 machinery is targeted for possible submission of comments in response.
Supreme Court Sets Date to Hear Tariff Suits for 5 November: On Thursday, 18 September, the Supreme Court posted the November hearing schedule that includes a date for the cases against President Trump’s International Emergency Economic Powers Act (IEEPA) tariffs scheduled for 5 November. The cases the judges are scheduled to hear are Learning Resources v. Trump and Trump v. V.O.S. Selections.
Trade Group Challenges Section 232 Expansion Over Cost and Uncertainty: On Tuesday, 16 September, the U.S. Chamber of Commerce published a letter from 43 trade groups to Jeffrey Kessler, the head of Commerce’s Bureau of Industry and Security (BIS) arguing that the agency’s expansion of steel and aluminum tariffs “was implemented without adequate notice and creates significant unintended costs, complexity, and uncertainty for U.S. businesses.”
The United Kingdom Pushes for 0% Tariffs on Steel Exports to the United States: On Tuesday, 16 September, the Financial Times reported that steel imports into the US from the UK may face 25% import duties as opposed to the 0% that was reported earlier in May. Prime Minister Keith Starmer hopes that the UK will be able to reach a 0% tariff quota for British steel exports as the UK continues to negotiate with the US. We will continue to monitor and update if the UK will receive any relief from U.S. Section 232 tariffs on steel.
Status of US Bilaterial Negotiations and Discussions: Please see the chart below for the latest on how certain countries are engaging with the United States in effort to reduce reciprocal tariffs and conclude bilateral deals.
Trade Policy Actions by Other Countries
Canada and Mexico Sign Action Plan of Ahead USMCA Review: On Friday, 19 September, the Government of Canada published details on the Canada-Mexico Action Plan 2025-2028. The Action Plan is a strategic partnership between the two countries that will strengthen bilaterial trade and promote mutual investment. As details are still forthcoming, it is unclear how PMMI members may benefit.
China’s Steel Exports to Reach Record High for 2025: On Tuesday, September 16, Bloomberg reported that China’s steel exports are expected to grow between 4%-9% in 2025 despite efforts by the US and other countries to slow down imports of steel from China. Bloomberg notes that steelmakers are maintaining this momentum by pivoting to markets where trade barriers are lower or nonexistent.
