CUSMA Compliance in 2026: What's Changed
CUSMA did not expire in July 2026. The agreement remains in force, and businesses should continue applying its current rules unless and until a formal change is implemented. Separate tariff measures still require their own product-level analysis.
- The first CUSMA joint review occurred in July 2026; it was a scheduled review, not an expiry or automatic renegotiation.
- Global Affairs Canada states that the agreement remains fully in force until 2036 while the parties continue the review process.
- Canadian exporters should keep classifying products correctly, applying product-specific rules of origin, and maintaining support for every certification.
- CUSMA qualification can preserve preferential treatment, but sector-specific tariffs may operate separately.
- A policy announcement does not change a compliance procedure until the relevant legal and customs instructions are issued.
The Canada-United States-Mexico Agreement entered into force on July 1, 2020. Its first six-year joint review occurred in July 2026 against an unusually difficult trade backdrop.
For businesses, the most important point is continuity: the joint review did not switch CUSMA off. Existing origin, certification, customs, labour, digital-trade, and dispute provisions continue to govern unless a change is formally adopted and implemented.
What the July 2026 Joint Review Actually Means
Under Article 34.7, the parties periodically review the operation of the agreement and consider whether to extend its term. The Government of Canada's joint-review overview emphasizes that the review is not an expiry date.
If all three parties confirm an extension, the term can be extended for another 16 years. If they do not reach that consensus, the agreement does not disappear immediately. Reviews can continue annually while the existing term runs to 2036.
Canada's July 3 ministerial readout says CUSMA remains fully in force until 2036 and that discussions continue, including on sectoral tariffs affecting steel, aluminum, automobiles, and softwood lumber.
What Has Not Changed for Day-to-Day Compliance
The review itself did not remove the need to:
- classify goods under the correct HS tariff provision;
- apply the product-specific rule of origin;
- calculate regional value content where required;
- obtain accurate supplier and production information;
- complete the certification of origin using the required data elements;
- retain the records supporting the claim;
- respond to customs verifications;
- correct unsupported claims.
This matters because political uncertainty can create a false sense that normal compliance work should wait. In reality, a business with weak origin support is less able to use CUSMA when preferential treatment is available and less able to adapt when another tariff measure changes.
The CUSMA Origin Decision
CUSMA does not make a good originating merely because it ships from Canada, the United States, or Mexico. The product must satisfy the agreement's rule.
For product-level mechanics, see our guide to understanding rules of origin under CUSMA.
Tariff Shift
Many product-specific rules require non-originating materials to undergo a specified change in tariff classification through North American production. A classification error in the finished good or an input can therefore change the origin result.
Regional Value Content
Some rules require a defined share of value to be generated in the region. The agreement uses prescribed methods, including transaction-value and net-cost approaches. Automotive goods have additional requirements and should not be assessed using a generic manufacturing example.
De Minimis
CUSMA includes de minimis rules that may allow a limited amount of non-originating material that does not meet the required tariff shift. The threshold and calculation depend on the product and sector; textile and apparel rules differ from the general rule.
CUSMA and Separate U.S. Tariffs
CUSMA qualification and additional tariff exposure are related but distinct questions.
- Does the good meet the product-specific origin rule?
- Is the certification complete and accurate?
- Can the exporter, producer, or importer support the claim?
- What preferential rate follows from qualification?
- Is the tariff item covered by Section 338, Section 232, or another action?
- Does the measure exempt or treat CUSMA goods differently?
- What entry date and customs instructions apply?
- Can any product exclusion, correction, or recovery mechanism apply?
Do not assume that CUSMA qualification removes every sector measure. Do not make the opposite mistake and abandon CUSMA certification because another measure may apply. Analyze both questions and document both conclusions.
Our updated guide to U.S. tariffs affecting Canadian exporters explains the current framework, while the dated September 2026 tariff briefing covers the newest bilateral measures.
Sector Issues to Watch After the Review
Automotive
Automotive origin rules include regional value content, core/principal/complementary parts rules, steel and aluminum purchase requirements, and labour-value requirements. Integrated supply chains can also be affected by separate vehicle and parts tariffs. Vehicle assemblers and suppliers should maintain line-level origin and content evidence and reconcile it with the tariff treatment actually applied.
Steel and Aluminum
Steel and aluminum businesses need to separate CUSMA origin from Section 232, derivative-product, quota, and trade-remedy analysis. Product composition and classification can determine whether a downstream item falls within an additional measure.
Agriculture and Dairy
Tariff-rate quotas, import permits, origin, and market-access commitments continue to make agricultural compliance product-specific. The 2026 tariff dispute has also shown that dairy policy can trigger broader trade action. Importers and exporters should monitor both CUSMA administration and separate tariff instruments.
Textiles and Apparel
Yarn-forward and other sector-specific rules require detailed material and production information. Tariff preference levels may provide limited alternative access for some non-originating goods, but they have their own eligibility and administrative requirements.
A Practical CUSMA Compliance Checklist
Working with Brokers, Counsel, and Advisors
A broker can support entry and customs processes. Counsel can advise on legal interpretation, disputes, and response strategy. A trade advisor can help connect origin, tariffs, supply chain, contracts, and management decisions.
The business should still own the underlying data. No external provider can create reliable origin evidence if procurement, engineering, finance, and operations cannot explain the bill of material and production process.
Someone who did not prepare the original claim should be able to open the file, identify the classification and rule, follow the calculation, locate supplier support, and reconcile the claim to the shipment. If that cannot be done, the file is not yet audit-ready.
What to Monitor Next
- formal statements from the CUSMA Free Trade Commission and the three governments;
- implementation documents for any agreed change;
- CBSA and CBP customs notices;
- sectoral tariff negotiations and product exclusions;
- origin-verification activity and published guidance;
- sourcing or production changes inside the business.
Treat press conferences and negotiating positions as signals, not operating rules. Change the compliance process only when the applicable agreement text, regulation, proclamation, tariff schedule, ruling, or customs instruction changes.
Ready to expand globally?
Senatus Group helps Canadian businesses navigate international markets, build strategic partnerships, and scale across borders.
Book a Free ConsultationWant to learn more first? Explore compliance services.
Frequently Asked Questions
This article provides general business information, not customs, legal, tax, or accounting advice.