A review with a sunset clause

The T-MEC (or USMCA) incorporates a sunset clause that obliges the United States, Mexico and Canada to confirm in 2026 their willingness to keep the agreement in force for another 16 years. If all three countries agree, the treaty will be extended until 2042; if one opposes, it will open a cycle of annual reviews for a decade, which would introduce high legal uncertainty for investment and business planning.

This design makes the review a powerful tool for political pressure from the United States, since the mere delay in renewal can raise doubts about the continuity of the trade framework.

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The main tension fronts

The United States has made it clear that the renewal will not be automatic and that it will require progress in several areas where there is friction with Mexico and Canada. These include rules of origin in the automotive sector, control of transhipment to prevent the indirect entry of Chinese products, and disagreements on energy and agriculture.

In addition to these elements, the intensive use of the Rapid Response Labor Mechanism has increased the supervision of labor conditions in Mexico and is emerging as another relevant negotiation axis.

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The political factor and the risk of hardening

The political context in the United States adds an additional layer of complexity. The influence of protectionist approaches and the threat of resorting to tariffs or bilateral agreements reinforce the perception that the review may result in substantial changes, even without a formal reopening of the entire treaty text.

Analysts agree that the threat of not renewing the agreement could be used to force concessions in strategic sectors, broadening the scope of the negotiation beyond the strictly commercial.

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Implications for European companies

For many European companies, the T-MEC has been a way to enter the U.S. market through investments and operations in Mexico or Canada. A possible tightening of conditions or a prolonged scenario of annual reviews would increase regulatory risk and uncertainty in value chains, affecting investment decisions, production location and market access.

In this context, the 2026 review is emerging as a critical point that companies will need to follow closely, not only because of its direct impact on North America, but also because of its potential indirect effects on international trade and investment.