Consumer Brands has a lot to be proud of in representing the makers of America’s food, beverage, household and personal care manufacturers. As the nation’s largest domestic manufacturing sector by employment, for example, the industry sustains more than 22 million American jobs and contributes more than $2.5 trillion to U.S. GDP annually.

What we’re proudest of, though, is not just that we make these everyday essential products right here in America, but that we also rely on U.S. farmers and suppliers for up to 90 percent of ingredients and inputs. Everyone knows the brands America loves in the grocery store, but what may not be as readily apparent is the degree to which the consumer packaged goods (CPG) industry is a true made-in-the-USA success story.

As the largest domestic manufacturing sector, we also have unique insight into the workings of the current United States-Mexico-Canada (USMCA) agreement, and how it has delivered substantial gains to U.S. manufacturers over the last six years. Canada and Mexico are huge markets for American CPG companies, and the assurance of continued duty-free trade in USMCA-compliant goods and renewed trilateral partnership is critical to continued growth and success. North American supply chains are deeply intertwined, and even manufacturers that vastly focus production in the United States strongly support swift renewal of USMCA and its benefits.

For Consumer Brands, it’s important to emphasize recommendations that would further bolster USMCA’s ability to deliver America First gains to U.S. manufacturers. While renewing core components and functionality of the agreement is paramount, we would also posit that this administration has demonstrated the ability to negotiate from a position of strength and secure trade deals that are advantageous to U.S. interests.

In renewing USMCA, then, there are also three primary opportunities for this type of America First action, which I’ll summarize here:

• Further recognition of unique sourcing needs from Canada and Mexico, particularly for unavailable natural resources and inputs lacking adequate domestic production. In turn, this may require more consistent and clear application of rules of origin, such as for cocoa and coffee products that are substantially transformed from their “green” / unprocessed state. As referenced in our submission, we view this as an opportunity to correct miscategorization and ROO determination, ensuring consistency and parity with respect to S. treatment of key agriculturally derived ingredients. This is in keeping with recent recognition of these products in both the president’s November 14 executive order modifying the scope of reciprocal tariffs, and the prior September 5 executive order establishing the original PTAAP list.
• Continued focus on convergence and reciprocal understanding of regulatory, legal, and safety requirements between jurisdictions. Across a market as large and significant as North America, it is not surprising that divergence of regulatory, legal and safety requirements hinder fluid movement of goods and services, and can compromise

U.S. manufacturer growth across the region. CPG companies most acutely feel these challenges as they relate to product safety and labeling rules. Similarly, regulatory divergence on packaging, recycling and extended producer responsibility policies adds unnecessary cost and complexity. Expanding mutual recognition of safety and product standards – particularly for food, beverage, household and personal care products – would better position U.S. manufacturers doing business in all three countries.

• Lastly, emphasize legal predictability, fairness and clarity. Trade agreements are only truly successful if they are adequately enforced. In its review, the Trump administration should emphasize the need for impartial review and adherence to due process; long-term monitoring of dispute resolution mechanisms; and the development of uniform training and guidance for customs authorities and regulators.

Taken together, these three opportunities are not intended to overlook the tremendous benefits of USMCA. Every effort should be made to renew and maintain North America’s unique trilateral trading relationship. The president’s signature trade accomplishment from his first term remains a true gold-standard, which is why we are excited as an industry to continue working with the administration to ensure its permanency and continued success.