The Office of the U.S. Trade Representative concluded three days of public hearings last week as part of the United States’ preparation for the 2026 six-year joint review of the United States-Mexico-Canada Agreement (USMCA). Held December 3–5 after being postponed from the originally scheduled November 17 date, the hearings followed an unusually high volume of participation: approximately 1,500 written comments and about 170 requests to testify. The expanded schedule allowed USTR to hear from more than 100 stakeholders across industry, labor, agriculture, academia, and civil-society organizations. Testimony, rebuttal filings, and written submissions will inform USTR’s report to Congress, which is statutorily due on January 2, 2026 and will help determine whether the Administration recommends renewing the agreement.
Stakeholders offered a wide range of assessments of USMCA’s performance since its entry into force. Business groups broadly supported continuation of the agreement, emphasizing the importance of predictable market access, integrated North American supply chains, and stable conditions for manufacturing and investment. Many industry witnesses encouraged renewal while suggesting targeted adjustments to enforcement mechanisms and technical provisions. Labor, environmental, and public-interest organizations presented more varied perspectives, with some highlighting implementation gaps and calling for strengthened labor and environmental standards.
Senior USTR officials also underscored the significance of the upcoming review. Speaking at a separate conference last week, USTR indicated that the joint review presents an opportunity to negotiate with Canada and Mexico on potential updates or clarifications to the pact. The agency also noted that the review process, including its sunset mechanism, naturally contemplates a full examination of whether the agreement should be maintained, modified, or allowed to expire—an option that, while rarely supported by stakeholders, remains part of the statutory framework.
High-level diplomatic engagement is already underway. President Trump reportedly met privately for approximately 45 minutes—with no staff present—with Canadian Prime Minister Pierre Poilievre’s representative, Deputy Prime Minister Chrystia Carney, and Mexican President Claudia Sheinbaum. While details of the discussion were not released, the meeting signaled early leader-level involvement ahead of next year’s trilateral review.
As USTR compiles its findings for Congress, the hearing record reflects both widespread support for renewing USMCA and ongoing debates about specific areas that may merit revision or enhanced enforcement. The Administration’s report on January 2 will help set the tone for negotiations with Canada and Mexico as the 2026 review approaches.
USTR Requests Public Comment for 2026 Review of USMCA Automotive Rules
The Office of the U.S. Trade Representative has opened a public comment period to support its upcoming review of the United States–Mexico–Canada Agreement’s automotive provisions. The request, published in the Federal Register on December 5, 2025, begins the third biennial review mandated by the USMCA Implementation Act, which requires USTR to submit a report to Congress on the operation of these provisions by July 1, 2026.
USTR is seeking detailed feedback on how the automotive rules of origin and related requirements have functioned since the agreement took effect. The agency invites comments on the implementation of regional value content calculations, steel and aluminum sourcing requirements, labor value content thresholds, and other elements that determine whether vehicles and parts are eligible for preferential tariff treatment under the USMCA.
The information gathered through the comment process will be used to inform USTR’s 2026 report, alongside data and assessments from previous implementation reviews. Submissions will help the agency evaluate compliance patterns, administrative or operational challenges, and the overall impact of the agreement’s automotive provisions on trade flows within North America.
This review is part of the broader oversight structure built into the USMCA to monitor the performance of sector-specific chapters—particularly those governing automotive goods—as the three countries prepare for the full six-year joint review of the agreement in 2026.
BIS Signals Section 232 Inclusion Decisions Will Slip to 2026 as New Petition Window Approaches
The Commerce Department’s Bureau of Industry and Security has signaled that it may not release the next Section 232 steel and aluminum inclusion list before the end of the year, with decisions now expected to slip into early 2026. The delay means stakeholders will likely enter the upcoming January 1, 2026, petition window without clarity on the status of the current round of requested inclusions—creating added uncertainty for importers, domestic producers, and downstream manufacturers that rely on the agency’s determinations for planning and compliance.
BIS earlier established the inclusion process as a successor to the former product exclusion system, allowing companies to petition for specific steel and aluminum products to be covered by the existing national-security tariffs. With the second-round decisions now deferred, parties may need to prepare new submissions while still awaiting outcomes from their earlier filings. While the agency has emphasized that the overall timetable for the process remains unchanged and that the third inclusion window will open as scheduled on January 1, the delay in decisions on covered inclusions from the second round could push the process further into January.
Education Department Launches Negotiated Rulemaking to Develop Workforce Pell Regulations
The U.S. Department of Education has begun the formal negotiated rulemaking process to develop regulations implementing Workforce Pell, the new federal aid expansion allowing students to use Pell Grants for short-term, workforce-focused training programs. The Department convened its rulemaking committee this week to review initial draft regulatory language and begin discussions on how to translate the statutory framework into operational policy. Workforce Pell, authorized under the One Big Beautiful Bill, will permit eligible programs of 8 to 15 weeks to qualify for federal aid if they lead to recognized, stackable credentials and meet specific quality benchmarks. The draft language outlines potential eligibility criteria, including state approval of programs, requirements for credentials to be portable and related to in-demand fields, and outcome-based accountability measures such as completion, job placement, and earnings metrics.
Committee members began reviewing issues central to program implementation, including how states will determine eligible programs, how institutions must document employment outcomes, and the extent to which noncredit or third-party training providers may participate. Several provisions remain open for discussion, such as the methodology for verifying job placement, how earnings thresholds will be calculated, and what data institutions and states must report. The Department has proposed an accelerated timeline for the Workforce Pell portion of the negotiations, indicating that it intends to complete the committee’s deliberations within a single week before shifting to additional higher-education topics in January. Some stakeholders have questioned whether this compressed schedule will allow adequate time for analysis and revision, noting the complexity of the new eligibility and accountability framework.
Following the December and January sessions, the Department is expected to issue a Notice of Proposed Rulemaking, which will open the draft regulations to public comment. Final rules are typically issued after the comment period and could take effect as early as July 2026, depending on timing and the Department’s implementation decisions. As negotiations proceed, states, institutions, and workforce partners are monitoring key questions that could shape program participation, such as the role of state workforce boards, the treatment of noncredit offerings, and the data systems required to measure student outcomes. The Department’s rulemaking decisions in the coming months will determine how Workforce Pell is implemented nationwide and how institutions prepare to offer short-term programs under the expanded Pell framework.
EPA Seeks Court Approval to Vacate Revised PM2.5 Standard
The Environmental Protection Agency has asked the U.S. Court of Appeals for the District of Columbia Circuit to vacate the tighter annual fine particulate matter (PM2.5) standard finalized in early 2024, citing legal and analytical errors in its development. In a motion filed in late November, EPA requested a ruling before February 7, 2026—the statutory deadline for issuing the first round of nonattainment designations under the revised limit of 9 micrograms per cubic meter. The agency stated that it “now confesses error,” noting that it should have more thoroughly reviewed the scientific criteria underpinning the standard and placed greater emphasis on the “extraordinary” compliance costs associated with meeting the lower threshold. EPA also acknowledged concerns raised by states and industry petitioners over the regulatory process used to establish the standard.
If the court grants the motion, the 2024 annual PM2.5 limit would be set aside, and EPA would be expected to revisit the rule through a new, full rulemaking process. The request comes as stakeholders prepare for potential nonattainment determinations that could carry significant permitting and planning implications for affected regions. Environmental groups have indicated they will oppose the motion, while manufacturers and other regulated sectors have welcomed EPA’s reassessment of the rule and its economic impacts. The court’s decision will determine whether the current standard remains in place as EPA approaches the February designation deadline.