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COMMENTS OF ITIF to the Office of the United States Trade Representative (USTR) Washington, D.C. November 3, 2025 CONTENTS Introduction and Summary.......................................................................................................................... 3The United States Should Support USMCA’s Renewal ................................................................................ 3The Case for a North American Production System.................................................................................. 3USMCA Is a Building Block of the United States’ Techno-Economic Power ............................................ 5Case Studies: USMCA Bolstering U.S. Competitiveness in Strategic Industries......................................... 7Semiconductors: Micron Technology’s Cross-Border Expansion........................................................... 7Automobiles: Engine of Ford’s Flagship Vehicle Ping-Pongs the Border................................................ 8Shielding USMCA From Chinese Mercantilism ........................................................................................... 8Reinforce FDI Screening and Information-Sharing Mechanisms............................................................... 8Tighten Regulations on Rules of Origin ................................................................................................... 8USMCA Partners Should Refrain From Entering Into Unilateral Trade Arrangements With China .......... 9 INTRODUCTION AND SUMMARY The Information Technology and Innovation Foundation (ITIF) is pleased to submit the followingcomments for consideration by the Office of the United States Trade Representative (USTR) for the jointreview (Joint Review) of the Agreement between the United States of America, the United Mexican States, ITIF urges the U.S. government to renew the USMCA. The USMCA strengthens America’s position to compete with China. First, it enables U.S. manufacturers to source inputs from Canada and Mexico at lowercost, as USMCA-qualifying goods—those meeting the agreement’s rules-of-origin (ROO) thresholds—movetariff-free across the region. Second, it helps weaken China’s manufacturing capacity by incentivizing firms toreshore production to North America and substitute Chinese imports with inputs or final products made USMCA renewal should reflect a modernized version of the existing agreement. First, the new agreementneeds concrete rules to shield the USMCA regional economy from Chinese predatory practices, includingstrengthening rules of origin rules and enforcement, implementing more commonly standardized investmentscreening practices, and allowing mechanisms to exclude IP mass infringers from the North Americaneconomy. Second, USMCA countries should jointly establish common goals to improve the region’scompetitiveness. Third, the current digital trade chapter should be modernized to include provisions onadopting emerging technologies and facilitating digital governance—for example, e-payments—and toaddress topics that currently define the North American digital economy, such as hardware and exportcontrols. Fourth, the agreement should continue to strengthen the rules underpinning IP rightsthroughout the region, particularly in the life sciences. This submission also incorporates suggestions on THE UNITED STATES SHOULD SUPPORT USMCA’S RENEWAL The U.S. government should take the lead and urge Canada and Mexico to continue the USMCA. Accordingto its original text, if the 2026 review of the agreement leads to renewal, USMCA shall continue in force for16 years, with a review in 2032. Alongside renewing the USMCA, the U.S. government should considerstarting negotiations to expand the USMCA to other economies in the Americas that can complement U.S.capabilities. Key candidates include existing bilateral free trade partners—Chile, Colombia, Panama, and The Case for a North American Production System The United States should make the development of a competitive North American Production System—a “factory North America”—the top priority. A stronger North American production system enhances U.S. techno-economic power by expanding regional manufacturing capacity and reducing dependence on Chinathrough reshoring and shifting trade flows from it. The three neighbors should work together to proactively support a North American production system, asinvestments, research and development (R&D), and trade among these countries are more likely to benefitothers in North America than production networks based in China. However, for this to happen, especially in The United States also needs to stop reflexively opposing U.S. firms that move or increase production inMexico. That’s because production in Mexico is fundamentally different from that in China. For example, 40 percent of the inputs to finished manufactured goods in Mexico come from the United States.1By contrast,for China, that figure is a mere 4 percent. In essenc