On January 7, 2026, SAFE submitted comments in response to the Office of the United States Trade Representative’s Request for Comments Concerning the Operation of the United States-Mexico-Canada Agreement With Respect To Trade in Automotive Goods.
As an organization committed to advancing American energy, economic, and national security, SAFE views USMCA as a central instrument for building resilient, regionally integrated supply chains that reduce strategic dependence on China. North America’s automotive sector is one of the most deeply integrated manufacturing ecosystems in the world, built over decades of cross-border specialization beginning with the 1965 Canada-U.S. Auto Pact and strengthened through NAFTA and now USMCA. Today, parts cross borders up to eight times before final assembly—an integration that underpins the global competitiveness of the region’s automotive industry.
USMCA’s rules of origin for autos and auto parts, the most rigorous ever applied, were designed to preserve this integration while ensuring its benefits accrue to North American workers and suppliers. By setting clear standards for content, labor, and sourcing, the rules aim to prevent circumvention, reinforce regional production, and align trade policy with the strategic goal of strengthening North America’s industrial base, and in extension, U.S. manufacturing competitiveness.
However, current enforcement challenges, including tariff circumvention, and recent tariff policies and reciprocal trade agreements, risk undermining North American manufacturing competitiveness and incentives for automotive and battery supply chains. In the comments, SAFE recommends implementing enhanced transparency and traceability measures, as well as modernizing classification and origination rules for batteries and motors. Through these steps, and by expanding domestic end-of-life vehicle recycling opportunities, the U.S. can strengthen its supply chain security for critical metals and materials.
Read SAFE’s full comments here.
