USTR Seeks Input on EU Carbon Border Adjustment Mechanism and USMCA Operation

The Office of the United States Trade Representative (USTR) has opened two public comment opportunities of interest to the U.S. standardization community.

EU Carbon Border Adjustment Mechanism

USTR is requesting comments on the EU’s Carbon Border Adjustment Mechanism (CBAM). CBAM requires EU importers of covered products in the aluminum, cement, electricity, fertilizer, hydrogen, and iron and steel sectors to declare those goods’ embedded greenhouse gas emissions and purchase certificates based on them. Company-level emissions data must be verified by an EU-accredited third party. The EU is also considering proposals to expand CBAM to hundreds of additional steel- and aluminum-intensive products.

In particular, USTR invites comments regarding:

• CBAM’s current impact on costs, regulatory burden, and EU market access for U.S. producers, including small- and medium-sized producers
• The potential impact of the EU’s proposals to expand CBAM coverage to additional products
• Whether CBAM disadvantages, advantages, or otherwise affects U.S. companies compared with EU or third-country companies
• Whether and what enforcement action may be appropriate to remedy any negative effects

USTR notes that comments may include specific compliance challenges, economic data, affected products and trade values, impacts on sales and jobs, and suggested changes to CBAM.

Comments are due via Regulations.gov (docket USTR-2026-0661) by November 9, 2026.

USMCA

USTR is also seeking comments on the operation of the Agreement between the United States of America, the United Mexican States, and Canada (USMCA) ahead of its 2027 annual joint review.

In particular, USTR invites comments regarding:

• Any aspect of the operation or implementation of the USMCA
• Any issues of compliance with the agreement
• Recommendations for specific actions USTR should propose ahead of the joint review
• Factors affecting the investment climate in North America, and the USMCA’s effectiveness in promoting investment that strengthens U.S. competitiveness, productivity, and technological leadership
• Strategies for strengthening North American economic security and competitiveness, including cooperation on non-market policies and practices of other countries

Comments and requests to appear at USTR’s public hearing are due via the USTR comment portal by January 12, 2027. Hearing details will be posted on USTR’s website.

China Section 301 Actions

USTR also published a notice on October 7 confirming that the 2018 Section 301 actions on China’s technology transfer, intellectual property, and innovation practices will remain in effect. A request for comments on those actions is expected in a separate notice.