Intro
As the Government of Canada prepares for the 2026 joint review of the Canada–United States–Mexico Agreement (CUSMA), the Calgary Chamber of Commerce is pleased to provide a submission on behalf our of members. Competitive, rules-based trade across North America is fundamental to Canada’s prosperity. CUSMA’s protection of Canada’s preferential access to American and Mexican markets has supported growth for businesses, consumers and governments across the continent.
Several aspects of the agreement have worked well. Provisions on digital trade have strengthened Alberta’s growing technology sector by prohibiting data localization and enabling cross-border data flows. These measures have provided certainty for business, encouraged investment and supported innovation across sectors.
The joint review presents an opportunity to modernize and strengthen CUSMA to ensure it continues to deliver tangible benefits for all three economies. As Canada’s trading relationship with the United States evolves under the current administration, it will be critical to focus on reducing barriers, resolving ongoing trade irritants and advancing a shared commitment to tariff-free trade across an integrated North American market.
Despite the successes, several challenges remain that risk undermining Canada’s competitiveness. Addressing these issues through the upcoming review will be key to ensuring CUSMA remains a strong foundation for North American economic growth.
Recommendations
CUSMA has delivered significant tangible benefits to Canadians. However, several issues continue to create uncertainty and limit North America’s ability to compete globally. The upcoming joint review presents an opportunity to strengthen the agreement, modernize its provisions and ensure it reflects today’s economic and geopolitical realities.
The Calgary Chamber recommends that the Canadian federal government prioritize the following areas during the review:
Energy Security and Green Investment Collaboration
Canada and the United States should continue enforcing the bilateral side letter on energy, recognizing the importance of an integrated North American energy market. In 2023, Canada supplied 60 per cent of U.S. crude oil imports. To reduce administrative burden, both governments should maintain and clarify CUSMA rules of origin for crude oil. The current 40% threshold for non-originating diluent in diluted bitumen reflects the current practice and should be upheld to ensure regulatory certainty and support continued cross-border energy trade.
The CUSMA review should reconsider investment protections to restore confidence in cross-border energy infrastructure and resource development. Current restrictions on investor–state dispute settlement (ISDS) provisions limit Canadian energy investors’ ability to challenge unfair or discriminatory treatment, creating uncertainty, particularly for organizations in Alberta’s oil and gas sector. This risk is compounded by Mexico’s preference for state-owned enterprises like PEMEX, which often sidelines foreign firms from key contracts and development opportunities Together, these factors threaten Canada’s competitiveness in the North American energy market and constrain opportunities for collaboration and growth across the sector.
Canada, the United States and Mexico should expand collaboration on clean energy and emerging technologies, including carbon capture, utilization and storage (CCUS), hydrogen and nuclear as it is critical for energy security, economic competitiveness and climate leadership. The review offers an opportunity to establish a North American energy security framework that attracts new investment, strengthens cross border trade and accelerates the transition to low-carbon energy.
Integrated North American Supply Chains for Critical Minerals
CUSMA should strengthen rules of origin to include critical minerals, batteries and electric vehicles (EVs), ensuring the entire value chain qualifies for preferential treatment. Alberta and Saskatchewan’s mineral resources position Canada as a reliable supplier for continental production, and with global demand for these inputs expected to double or quadruple by 2040, North American integration is essential. Mexico’s state control over lithium reserves remains a barrier to a fully integrated supply chain, while reliance on China is a growing vulnerability: China supplies over 50 per cent of U.S. demand for 21 nonfuel minerals. Strengthening regional collaboration is crucial to secure key inputs such as lithium, cobalt and nickel, reduce dependence on China and ensure a resilient North American supply chain.
Digital and Regulatory Alignment
Canada should pursue trilateral alignment on standards and regulations to reduce duplication and enhance interoperability across sectors. Alberta and Calgary’s growing technology industry benefits from the prohibition of data localization under CUSMA, which allows companies to transfer data freely across borders. This has strengthened cross-border collaboration and supported innovation.
However, privacy concerns and differing regulatory frameworks between Canada and the United States create challenges for Alberta and Calgary-based firms in highly sensitive sectors such as aviation, defence, fintech and health technology. While our technology firms benefit from greater access to North American markets, the absence of stringent localization policies in the United States and ongoing concerns around data privacy may limit growth in regulated industries.
Although CUSMA supports digital trade, regulatory misalignment remains a key barrier. Differences in data privacy and digital legislation continue to create friction with U.S. counterparts. Greater coordination is needed to ensure regulatory consistency that protects privacy while enabling innovation and competitiveness across North America.
Agriculture and Agrifood
CUSMA member states should continue to enhance market access for agriculture and agri-food products. The review presents an opportunity to expand trade in agricultural commodities not subject to supply management, such as pulses, beef, wheat and canola. This would open new market opportunities for agricultural products grown across Western Canada, which accounts for 90 per cent of the country’s total crop area.
Persistent trade irritants, and the threat of new ones, must be addressed to provide predictability and stability for exporters. The reintroduction of Mandatory Country of Origin Labelling (M-COOL) for beef exports should be firmly opposed. Prior to its repeal, M-COOL imposed significant costs on Canada’s beef industry, resulting in estimated losses of $1 billion. Such measures create uncertainty, disrupt the integrated North American supply chains, and undermine the competitiveness of Canadian exporters.
Canada should collaborate with Mexico to ensure an open market for canola, a genetically modified crop that is an important product for the Canadian economy. Mexico’s prohibition on GMO canola is inconsistent with CUSMA’s principles of open, rules-based and science-informed trade. Canola ranks among Alberta’s top three exports, and Canadian crop production contributed $24.6 billion to Canada’s GDP, supported more than 100,000 jobs in 2024.
Labour Mobility and Immigration
Canada should advance reciprocal credential recognition frameworks with the United States and Mexico to reduce red tape, improve access to skilled talent and ensure expertise can move freely to support competitiveness and growth across the continent. Persistent shortages in skilled trades, healthcare and technology continue to constrain Canada’s economy. Strengthening cross-border credential recognition will help address labour shortages across North America.
CUSMA states should modernize the labour mobility provisions by expanding the Professionals List to include roles in new and emerging sectors such as AI specialists, cybersecurity experts, data analysts and renewable energy engineers. Streamlined processing for short-term business travel and cross-border project work is essential to maintaining supply chain continuity and enabling innovation.
Support for Small and Medium-Sized Enterprises (SMEs)
Canada must work with the United States to reinstate the de minimis threshold to support cross-border trade and competitiveness. Small and medium-sized enterprises (SMEs) are critical to Canada’s trade relationship with the United States. 42 per cent of Albertan exports went to the United States in 2024. Of those, 80 per cent of export revenue came directly from U.S. markets. These businesses are disproportionately affected by trade disruptions and regulatory shifts as they are unable to absorb increased costs, diversify suppliers quickly or navigate through complex trade disputes easily.
To ensure the CUSMA review process reflects the realities of businesses of all sizes, the federal government must engage SMEs directly to assess their exposure to potential rule changes, identify barriers to market access and strengthen their participation in North American supply chains.
Tariffs, Retaliatory Measures and Trade Stability
CUSMA members should exempt all qualifying products from unilateral or retaliatory tariffs, such as those imposed under Section 232 of the U.S. Trade Expansion Act and Section 301 of the U.S. Trade Act, to safeguard cross-border trade from economic unpredictability. For example, after the U.S. imposed tariffs on Canadian steel and aluminum in 2018, Canada’s exports in those sectors fell by 38 per cent.
The repeated threat and imposition of tariffs create ripple effects across the economy, particularly for small and medium-sized enterprises (SMEs). Firms that import from or export to the United States are increasingly viewed as high-risk, leading to higher interest rates and insurance costs. As a result, SMEs are being unfairly categorized as volatile despite their critical role in cross-border trade.
Strengthening exemption commitments would provide greater certainty for primary and secondary industries, protect supply chains from political volatility and support business confidence across North America.
Closing
CUSMA has delivered significant benefits for Canadian businesses and the broader economy, but challenges remain that, if unaddressed, could undermine Canada’s competitiveness in North America. The upcoming review offers an opportunity to modernize the agreement, strengthen market access and support energy security, innovation and cross-border trade. By taking decisive action on these priorities, Canada can ensure CUSMA continues to provide certainty, foster investment and drive sustainable growth for businesses of all sizes.
About the Calgary Chamber of Commerce
The Calgary Chamber exists to empower our business community to advance a prosperous Calgary and Canada. As the convenor and catalyst for a vibrant, inclusive and prosperous business community, the Chamber works to build strength and resilience among its members and position Calgary as a magnet for talent, diversification and opportunity. As an independent, non-profit, non-partisan organization founded in 1891, we build on our history to serve and advocate for businesses of all sizes, in all sectors across the city.
