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Overview
The Institute for Agriculture and Trade Policy (IATP) appreciates this opportunity to comment on aspects of the United States-Mexico-Canada Agreement (USMCA), and to assist the United States International Trade Commission (USITC) in completing the report required by Sec. 105. IATP last wrote to the USITC on February 16, 2016, regarding the proposed Trans-Pacific Partnership Agreement (TPPA). Part of the following analysis on non-tariff measure impacts are drawn from this TPPA analysis, insofar as many of the provisions of the USMCA were derived from the TPPA. Since its inception, the North American Free Trade Agreement (NAFTA) has been promoted as a means toward expanding U.S. agricultural exports, which presumably would result in a prosperous U.S. farm economy. The falling U.S. net farm income of the past five years cannot be reversed by U.S. agricultural policies designed to keep prices low, often below the cost of production, to “compete” with the same commodities from other major agricultural exporting countries. Unfortunately, with respect to agricultural policy, the USMCA continues the flawed approach of the original NAFTA. Changing trade policy to prevent U.S. agricultural export dumping will not by itself change U.S. agricultural policy to make it more market-based and less dependent on government payments. That change does not end with change to the terms of the USMCA, but it could begin there.
In the following comments, we first address a major flaw at the heart of the USMCA: Its failure to account for, and to address, the negative and sweeping impacts of climate change on the U.S. economy, especially on the agricultural sector. Next, we review the current state of the U.S. farm economy and the likely impact of the USMCA’s overall approach, which fails to address the serious underlying weaknesses of the agricultural sector of economy, instead continuing the policies promoted in the original NAFTA. We then analyze several sections of the USMCA of particular concern: The provisions on agricultural biotechnology; the sanitary and phytosanitary chapter; intellectual property provisions relating to agricultural chemicals; sectoral annexes to the chapter on technical barriers to trade; and the chapter on good regulatory practices. We focus particularly on whether these provisions will protect and advance “the interests of United States consumers” in the context of the institutional capacity—or lack of capacity—of U.S. agencies to implement the terms of the USMCA.
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