The American Coatings Association has sent a letter dated November 3 2025 to Ambassador Jamieson Greer and Daniel Watson at the Office of the United States Trade Representative in response to the request for comments on the operation of the United States-Mexico-Canada Agreement. In the letter, ACA expresses support for the USMCA and the joint review process outlined in Article 34.7 and describes benefits such as tariff-free markets, digital trade provisions, streamlined import-document submission and higher de minimis shipment values.

ACA notes that Canada and Mexico are the two largest trading partners for the U.S. paint and coatings industry, with $2.1 billion in exports to those countries in 2023, accounting for 70% of all U.S. paint and coatings exports. The letter recommends extending the USMCA for 10 to 16 years, preserving key tax and tariff provisions and focusing on implementation rather than broad renegotiation.

ACA also recommends changes related to rules of origin, including allowing manufacturers to use the Mixtures and Blends Rule 3 for paint products, revising rules of origin to allow transformation at the subheading level and treating HTS 3208 in the same way as HTS 3206 and 3212. In addition, ACA urges retention of the de minimis option in Article 4.12 and recommends increasing the threshold from 10% to 12.

The letter notes that the $32 billion coatings industry relies on access to certain raw materials and critical minerals that are not available in the United States and that these preferential tariff provisions should be preserved.

The letter is signed by Heidi K. McAuliffe, vice president of government affairs, who provides her contact information for questions about the impact of the USMCA on the coatings industry.