The following public comments were submitted by IATP, the National Family Farm Coalition (NFFC), and the Western Organization of Resource Councils (WORC) on October 28, 2025 to the Office of the U.S. Trade Representative as a Request for Public Comments and Notice of Public Hearing Relating to the Operation of the Agreement between the United States of America, the United Mexican States, and Canada.
Dear Ambassador Greer,
The Institute for Agriculture and Trade Policy (IATP), the National Family Farm Coalition (NFFC), and the Western Organization of Resource Councils (WORC) appreciate the opportunity to comment on the review of the U.S.-Mexico-Canada Agreement (USMCA). IATP is a non-profit organization based in Minneapolis, Minnesota with offices in Washington, D.C. and Berlin, Germany. IATP works locally and globally at the intersection of policy and practice to ensure fair and sustainable food, farm and trade systems. NFFC is an alliance of 30 grassroots farmer- and advocate-led groups across the United States representing the rights and interests of over 100,000 independent family farmers, ranchers, and fishermen. WORC is a regional network of grassroots community organizations that include 22,750 members and 38 local chapters.
We urge you to utilize the USMCA review process to correct fundamental problems in the agreement that affect farmers, consumers and rural communities. This is an important opportunity to address changes since the agreement was enacted in 2020 and to fix problems that have become apparent during its implementation. We support the changes called for in a June 12 letter from more than 680 civil society groups,i particularly the demands to strengthen labor and environmental rights in the agreement, to address the root causes of migration and displacement, to stop abuses of digital trade by big technology companies, to shut down special rights for foreign investors, and to make medicines affordable. We also support calls from environmental and other organizations to ensure that countries can meet their obligations under the Paris Agreement of the United Nations Conference on Climate Change, as well as human rights instruments including the United Nations Declaration on the Rights of Indigenous Peoples and the United Nations Declaration on the Rights of Peasants and Other People Working in Rural Areas, free from challenges under trade accords.
In addition, we call for new approaches to food and agriculture. Changing USMCA provisions that limit transparency, stifle innovations by farmers, and undermine rural livelihoods should be top priorities in the review.
Specifically, we call on negotiators to:
- Improve transparency in food labels: Amend Chapter 11 on Technical Barriers to Trade to add a “Peace Clause” Annex on Transparency in Food Labeling in which Canada, Mexico and the U.S. agree not to challenge each other’s labeling policies under trade rules in USMCA and the World Trade Organization (WTO) until a permanent solution can be found. This would include measures important to all three countries, including mandatory Country of Origin Labeling (COOL) for meat, nutrition, and GMO labeling. Parties to the USMCA should also commit to negotiations to permanently carve out measures related to transparency in food labeling from trade disputes.
- Encourage innovative seed systems: Remove the requirement in Chapter 20 on Intellectual Property Rights that each Party ratify UPOV 91, a restrictive treaty that prohibits farmers from saving and sharing protected seeds, thus greatly restricting their ability to develop new varieties that meet their specific needs and respond to changing climate conditions.
- Develop new solutions to overproduction and low prices of dairy and other agricultural commodities. This is a complex problem that will require changes to U.S. farm programs, but changes in trade policy are also relevant. As a starting point, the U.S. should abandon its trade challenges to Canada’s dairy supply management program and instead convene a participatory trinational commission to learn from that and other public programs designed to stabilize prices and supplies and enhance resilient food systems.
To continue reading, please download a PDF of the full comments.
i Civil society letter available at the Trade Justice Education Fund website: https://tradejusticeedfund.org/wp-content/uploads/USMCAReview_OrgSignOnLetter_061225.pdf?link_id=0&can_id=f48f8c8e93c0ed7f51482469ee613afd&source=email-statement-on-chinas-trade-challenge-against-the-inflation-reduction-act-ira-2&email_referrer=email_2776981&email_subject=statement-on-us-mexico-canada-trade-as-north-american-leaders-meet&&
