ICPA distinguishes controlling law, official government positions, stakeholder recommendations, media reporting, and ICPA analysis throughout this page. Negotiations do not alter an importer’s legal obligations unless implemented through an applicable legal mechanism.
No change to the current USMCA agriculture rules has been identified as legally effective as of July 19, 2026. Current obligations remain governed by USMCA Chapter 3 (Agriculture), Annex 3-A and Appendix 3-A.2, Chapter 9 (Sanitary and Phytosanitary Measures), Chapter 11 (Technical Barriers to Trade), and each country’s domestic implementing law unless and until a legally effective change is adopted.
Everything a compliance professional needs before the details.
North American agricultural trade is highly integrated and commercially significant — Mexico was the largest U.S. agricultural trading partner in 2025 at roughly $74.5 billion in two-way trade, with Canada close behind at roughly $67.5 billion. Agriculture is also responsible for two of USMCA’s most consequential state-to-state disputes to date: Canadian dairy tariff-rate quotas and Mexico’s genetically engineered corn restrictions. Any review outcome reaches directly into market access, SPS compliance, and origin documentation for agricultural goods.
The U.S. declined to renew USMCA in its current form on July 1, 2026, triggering annual reviews through 2036. A Chapter 31 panel ruled against Mexico on December 20, 2024, finding its genetically engineered corn measures inconsistent with multiple SPS obligations. A second U.S.–Canada dairy TRQ panel largely rejected U.S. claims in November 2023, following an earlier 2021 panel that ruled against Canada’s processor-reserved quota pools. Bilateral U.S.–Mexico negotiations were continuing as of July 19, 2026, with another round expected the week of July 20.
Reporting and stakeholder testimony point to possible U.S. pressure for more prescriptive Canadian dairy TRQ allocation language, minimum allocations for distributors and retailers, and stronger fill-rate requirements. Separately, seasonal-produce trade-remedy reforms affecting Mexican fruit and vegetable exports have circulated as a political proposal. ICPA has not located enacted text for either and has flagged them below as reported, not confirmed.
Potential areas of change include Canadian dairy TRQ administration rules, treatment of biotechnology and gene-edited products, seasonal and perishable-produce trade-remedy standards, country-of-origin labeling for meat and livestock, pesticide and maximum-residue-limit divergence, and cooperation mechanisms for animal-health emergencies such as New World screwworm. None of these have been adopted as legally effective changes.
Confirm current TRQ utilization, SPS certificate requirements, and origin documentation for agricultural shipments; monitor animal- and plant-health emergency restrictions that can shift border treatment quickly regardless of the broader review.
Do not revise TRQ compliance strategy, labeling programs, or biotechnology approval assumptions based on reported figures or stakeholder proposals alone.
Agriculture is a critical review area because North American agricultural trade is highly integrated and already responsible for two of USMCA’s most important state-to-state disputes: Canadian dairy tariff-rate quotas and Mexico’s restrictions on genetically engineered corn. The portfolio extends beyond Chapter 3 to include market access and TRQs under Chapters 2 and 3, sanitary and phytosanitary measures under Chapter 9, agricultural biotechnology under Chapter 3 Section B, technical regulations and labeling under Chapter 11, geographical indications under Chapter 20, and customs administration and origin verification for agricultural goods.
U.S. agricultural exports to Mexico reached approximately $30.6 billion in 2025, while imports from Mexico reached approximately $43.9 billion. Globally, U.S. agricultural imports exceeded exports by approximately $41 billion in 2025. A bilateral agricultural deficit does not itself establish a treaty violation; commodity composition, seasonality, and supply-chain specialization all factor into the picture.
For compliance teams, the immediate legal requirements remain unchanged unless and until the parties adopt a legally effective amendment, decision, regulation, or other implementing measure. Potential changes could nevertheless affect TRQ administration, SPS certification, biotechnology approval timelines, labeling requirements, and border clearance for perishable and agricultural goods.
The legal texts that govern agricultural trade today, unaffected by ongoing negotiations.
- Committee on Agricultural Trade records (not separately published)
- Committee on Sanitary and Phytosanitary Measures records (not separately published)
- Free Trade Commission decisions ↗
- Chapter 31 dispute records (dairy & GE corn) ↗
- USDA Economic Research Service — USMCA agriculture ↗
- USDA Foreign Agricultural Service ↗
- APHIS & FSIS regulations and notices
- USTR agriculture issue area ↗
- USITC agricultural-trade reports ↗
- Secretaría de Economía ↗
- Secretaría de Agricultura y Desarrollo Rural (SADER)
- SENASICA & COFEPRIS notices
- Diario Oficial de la Federación — GE corn decree & panel ↗
- CUSMA Chapter 3 implementing text ↗
- Agriculture and Agri-Food Canada notices
- Canadian Food Inspection Agency (CFIA)
- Global Affairs Canada — dairy TRQ materials ↗
The most consequential comparisons on this page. Nothing here is legally effective unless labeled “confirmed by controlling authority.”
Canada administers dairy TRQs under Appendix 3-A.2, with a November 2023 panel confirming Canada’s discretion to limit eligible applicants to processors, distributors, and further processors under Article 3.A.2.6(a).
U.S. dairy organizations are reportedly pressing for more prescriptive allocation language, minimum allocations for distributors and retailers, and stronger fill-rate and reallocation requirements. Not located in published negotiating text.
A Chapter 31 panel ruled on December 20, 2024 that Mexico’s February 2023 decree restricting genetically engineered corn was inconsistent with multiple SPS obligations, including risk-assessment and necessity requirements.
A publicly agreed compliance measure or implementation agreement has not been located. Mexico has continued to emphasize native-corn protection and food sovereignty even after the adverse ruling.
Seasonal and perishable Mexican produce (e.g., tomatoes) is managed largely through existing U.S. antidumping and countervailing-duty law and suspension agreements, outside USMCA Chapter 3 itself.
Certain U.S. producers have sought changes making it easier to bring antidumping or countervailing-duty cases based on regional or seasonal injury. Mexican exporters generally oppose this. No specific legal text located.
Resolved litigation that remains highly relevant to how the review may unfold.
United States v. Mexico
Articles 2.11, 9.6.3, 9.6.6, 9.6.10, 9.6.14
Mexico’s February 13, 2023 decree restricted genetically engineered corn for tortillas and dough and directed gradual substitution in animal feed and other uses. The United States argued the measures restricted imports in violation of Article 2.11 and were not properly grounded in a risk assessment under Chapter 9.
On December 20, 2024, the panel found Mexico had not conducted a qualifying risk assessment, that the measures were not adequately based on scientific principles, that they exceeded what was necessary, and that they were more trade restrictive than required — including a finding that the measures were applied beyond the extent necessary under Article 9.6.6(a). Confirmed
Mexico publicly emphasized the cultural, biodiversity, and food-sovereignty importance of native corn even after the adverse decision. ICPA has not located a published compliance measure or U.S. assessment of full compliance as of July 19, 2026.
The case is a leading precedent on science-based SPS regulation, the evidentiary burden for precautionary restrictions, and the relationship between cultural or biodiversity objectives and SPS disciplines. Any Mexican proposal for procedural protections around native corn would need to be squared with this ruling.
United States v. Canada
Appendix 3-A.2, Articles 3.A.2.4, 3.A.2.6, 3.A.2.11
The United States challenged whether Canada’s dairy TRQ allocation methods allowed commercially meaningful access or instead channeled quota primarily through Canadian processors whose interests could discourage imports. A first panel addressed processor-reserved pools; after Canada revised its policies, the U.S. brought a second challenge to the replacement system.
The first panel found Canada’s exclusive reservation of dairy TRQ portions for processors inconsistent with Article 3.A.2.11(b). In the second dispute, decided November 10, 2023, the panel largely rejected the U.S. claims, finding Article 3.A.2.6(a) did not prohibit Canada from limiting applicants to processors, distributors, and further processors, and rejecting the claim that Canada’s market-share system violated Article 3.A.2.11(b). Confirmed
Canada’s current dairy TRQ administration reflects the outcome of the second panel. No further Chapter 31 proceeding on this issue has been located as of July 19, 2026.
The contrast between the U.S. win in the first panel and its loss in the second illustrates how much regulatory discretion existing treaty language leaves Canada. This is likely to shape U.S. negotiating strategy toward clearer, more prescriptive allocation and fill-rate language rather than a new dispute under current text.
The broader set of recurring and developing issues ICPA is tracking beyond the two headline disputes.
- Canadian supply management (dairy, poultry, eggs)
- Agricultural-biotechnology approval delays
- Animal-health restrictions & New World screwworm
- Plant-health & horticultural restrictions
- Tomato suspension-agreement disputes
- Sugar & sweetener trade arrangements
- Meat & livestock country-of-origin labeling
- Pesticides, MRLs & glyphosate divergence
- Organic-standards equivalence
- Geographical indications & common food names
- Front-of-package & nutrition labeling
- Fertilizer, feed & seed input security
- Confirm current TRQ utilization & fill rates
- Review SPS certificate & risk-assessment documentation
- Track animal- and plant-health emergency restrictions
- Monitor biotechnology & gene-edited approval timelines
- Watch tomato & sugar suspension-agreement status
- Review labeling programs against pending proposals
- Confirm origin documentation for processed foods
- Identify perishable shipments exposed to border delays
Formal positions inferred only from official statements, not from press reporting or meeting attendance alone.
Seeks commercially meaningful Canadian dairy access, full compliance with the GE corn ruling, science-based SPS regulation, and reduced agricultural trade barriers. Emphasizes trade deficits, supply-chain resilience, and reciprocal market access. Declined to renew USMCA in its current form on July 1, 2026.
Protects native corn, biodiversity, and food sovereignty as domestic policy priorities while formally addressing the GE corn ruling. Defends produce and food-export access and opposes seasonal trade-remedy reforms.
Defends supply management and TRQ administration discretion, consistent with the November 2023 panel outcome. Generally supports predictable, science-based biotechnology approval systems and continental trade stability.
USDA Economic Research Service figures for 2025. Reported trade data, not modeled projections.
| Measure | 2025 figure |
|---|---|
| Total U.S.–Mexico two-way agricultural trade | ~$74.5 billion |
| Total U.S.–Canada two-way agricultural trade | ~$67.5 billion |
| U.S. agricultural exports to Mexico | ~$30.6 billion |
| U.S. agricultural imports from Mexico | ~$43.9 billion |
| Global U.S. agricultural trade balance | −$41 billion (imports exceed exports) |
Source: USDA Economic Research Service. A bilateral or global agricultural trade deficit does not itself establish a treaty violation or unfair practice — commodity composition, seasonality, climate, exchange rates, and supply-chain specialization all factor into these figures.
Extended to entry into force. Distinguishes negotiation, implementation, dispute, and economic-report events.
Reviewed and updated with each page verification pass.
- A comprehensive public agriculture agenda from the July 1, 2026 joint-review meeting has not been located
- A definitive public statement identifying Mexico’s post-ruling compliance measures, and a U.S. assessment of full compliance, has not been located
- A publicly agreed resolution memorializing the outcome of the second U.S.–Canada dairy dispute has not been located beyond the panel report itself
- Exact figures behind reported Canadian TRQ allocation demands are not confirmed by government source
- Specific legal text for seasonal-produce trade-remedy proposals has not been located
- A consolidated record of SPS committee concerns raised since July 2020 has not been located
- Complete bilateral negotiating texts or draft amendments under consideration in July 2026 have not been located
Get the weekly change log
Members receive a topic-by-topic diff every week, with confidence-tagged findings and full citations, before it’s posted here.
ICPA’s trade law partners can help members navigate TRQ compliance, SPS documentation, and biotechnology import requirements as this topic develops.
About this tracker
Spot something inaccurate, know of a development, article, or video that should be added, or notice something not working? Reach out any time.
This tracker is researched, written, and maintained by Heather Tschirhart, Head of Research, Data, and Analytics.