WASHINGTON, D.C. — The Coalition for a Prosperous America (CPA) today publicly released its comments submitted to the United States Trade Representative (USTR) as part of the statutory review of the U.S.–Mexico–Canada Agreement (USMCA). CPA’s submission, “Ensuring U.S. Sovereignty in North American Trade,” concludes that the current trilateral USMCA framework binds two vastly different economies to one unenforceable system—with each reliant on the far larger U.S. consumer market. This design leaves U.S. domestic producers exposed, cripples U.S. trade sovereignty, and prevents tailored responses.
CPA’s comments make a clear case for structural reform. NAFTA (signed in 1992 and enacted in 1994) and USMCA (in 2020) were each sold as engines of shared prosperity for the three largest countries in North America. Instead, these agreements have displaced between 500,000 and 700,000 U.S. jobs—primarily in manufacturing. The Economic Policy Institute has estimated 682,900 U.S. jobs were lost directly due to NAFTA, with 60% of those coming in manufacturing. The Keystone Research Center found total losses nearing 879,000, including 687,000 in just manufacturing. Such losses have been concentrated in the regions that once anchored the American middle class—motor vehicles, electronics, apparel, and steel.
KEY RECOMMENDATIONS:
U.S.–Mexico Agreement
- Enforce automatic, U.S.-administered quotas and strict oversight of Chinese investment and transshipment to protect U.S. manufacturers from ultra-cheap imports.
This would protect U.S. manufacturers from ultra-cheap imports from Mexico by prioritizing automatic enforcement, U.S.-administered quotas, and strict oversight of Chinese investment and transshipment.
U.S.–Canada Agreement
- Maintain market access for a developed ally while imposing binding safeguards against subsidized products and market displacement.
This would recognize Canada’s developed-market sophistication but imposes binding safeguards for U.S. industry against subsidized products and market displacement.
The United States should replace the flawed trilateral USMCA with two bilateral agreements. CPA agrees with President Trump’s suggestion to restructure USMCA in this way, and as the President recently stated, “We can renegotiate it, and that would be good, or we could just do different deals…We might make deals that are better for the individual countries.” Ontario Premier Doug Ford has expressed the same, supporting a bilateral agreement with the United States without Mexico.
“To defend our sovereignty, industries, and workers, America must fundamentally restructure its North American trade architecture,” said Jon Toomey, President of CPA. “The trilateral model didn’t work under NAFTA, and it isn’t working under USMCA. Both Canada and Mexico continue to exploit U.S. market access—Canada through subsidies and quotas, Mexico through dumping and transshipment. It’s time to replace compromise with control: two clear, enforceable bilateral deals that put American producers first.”
From NAFTA to the USMCA, trade imbalances have persisted and grown. Canada has weaponized dairy quotas and provincial control regimes to undermine U.S. producers, defy dispute rulings, and subsidize energy-intensive industries like aluminum. Mexico has flooded U.S. markets with dumped goods, violated voluntary export caps, and become a transshipment hub for Chinese components.
“When it comes to the USMCA, the activities of each of these trading partners to get a leg up on the U.S. has been made abundantly clear,” said report author CPA Economist Andrew Rechenberg. “With Canada, their actions—such as manipulating dairy quotas, subsidizing aluminum, and distorting softwood lumber markets—reflect industrial policy typical of a developed competitor. And with Mexico—whose violations range from steel and tomato dumping, to an alarming increase in transshipment of Chinese goods—represent systemic evasion and price undercutting by a developing-country exporter exploiting weak U.S. enforcement and market access.”
CPA’s submission outlines how Mexico has systemically undermined U.S. producers and workers by exploiting its trade status with the U.S. Across all sectors, Mexico’s approach has remained consistent: violate, delay, renegotiate, and repeat. This similar behavior appears across a wide range of sectors clearly show this as a deliberate model of noncompliance set out to undermine U.S. industries and the credibility of multilateral enforcement. CPA’s comments highlight specific Mexican systemic violations and evasion of trade obligations, including: steel and conduit, motor vehicles and auto parts, medium and heavy-duty trucks, agriculture, fruit and vegetable trade, tomatoes, sugar access, and beef and cattle.
CPA also shows that Canada is a problematic trade partner. Canada is a developed industrial competitor, and CPA’s comments look into a number of industries where Canada is displacing U.S. producers, including: aluminum and energy subsidies, softwood lumber, beef and cattle, and agriculture. CPA documents how the U.S.–Canada relationship must evolve from assumption of trust to structured protection against subsidized exports and market support for U.S. producers.
CPA’s comments further illustrate how a single framework for both partners has proven unworkable. Separate agreements would now allow the United States to calibrate enforcement mechanisms specific to each partner‘s behavior and trade relationship:
- Mexico: A developing exporter requiring automatic U.S.-administered enforcement to curb cheap products undercutting U.S. manufacturers.
- Canada: A developed competitor requiring safeguards to curb industrial policies and state aid.
Finally, CPA’s comments show how restoring quotas stabilized the U.S. sugar industry and why this offers a clear lesson for U.S. trade policy for agreements between Mexico and Canada moving forward. Specifically, the history of U.S. sugar trade shows how a transition away from free trade—to managed trade—can achieve more effective results for U.S. producers.
Download the full comments: Click here to read “CPA Comments Relating to the Operation of the Agreement Between the United States of America, the United Mexican States, and Canada: Ensuring U.S. Sovereignty in North American Trade.”
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