Submission on the Canada-United States-Mexico Agreement

To whom it may concern,

Pulse Canada strongly supports the Canada United States Mexico Agreement’s (CUSMA) continued implementation and preservation of its core framework including its trilateral scope, zero tariff access, a robust Sanitary and Phytosanitary (SPS) chapter, and an effective dispute settlement mechanism. Our sector relies on predictable, rules-based trade to maintain our position as a global leader in sustainable pulse production and the core framework provided by CUSMA is integral to the competitiveness, stability and the long-term security of the North American pulse market.

Pulse Canada represents Canada’s 26,000 growers of pulses (peas, lentils, chickpeas, dry beans, and faba beans), and the 110 processors, exporters and ingredient manufacturers (protein, flour, fibre, starch) of pulses and special crops (canary, mustard, buckwheat, and sunflower seed). Together, the pulse sector contributes $11 billion to Canada’s economy and contributes over 38,000 jobs (in addition to the farm families pulse production supports).

A strong North American trading block, anchored by CUSMA, is critical to Canada’s pulse and special crop sector.

Canada’s pulse sector has grown alongside, first, the North American Free Trade Agreement and now CUSMA. In 1995, Canada produced 2.6 million metric tonnes (MT) of pulses and special crops. In 2025, production was 7.6 million MT. Today, a value-added sector exists throughout Canada processing pulses into ingredients or manufacturing pulses and special crops into food, feed and pet food creating jobs, benefits to local communities and nutritious, healthy food for Canadians and the world. Core to farmers’ crop rotations, pulse production supports our environment by reducing greenhouse gas emissions and creating more resilient food systems.

In 2024, the United States was Canada’s second largest market purchasing $436 million in Canadian pulses and our fourth largest market volume-wise underlining the high-value nature of the North American market. Mexico is consistently a top market for Canadian beans complimenting Mexico’s supply, particularly when production is short and/or regional shortfalls exist. Additionally, the US is the number one market for pulse ingredients purchasing over 80% of Canadian pulse flour, fibre, starch, and protein. Conversely, Canada is the second largest market for US pulses (after Mexico).

CUSMA supports an integrated, continental pulse supply chain and transportation network. Canadian and American pulses move across borders depending on end-use segment and geographic market. US pulses travel North to be cleaned, processed and re-exported, while Canadian pulses, pulse ingredients and special crops are key inputs in US and Mexico food and feed production. Canadian farmers import seed, fertilizer and agriculture machinery from the US (and vice versa). For example, pulse farmers import bean seed from the US, benefitting from different growing conditions (arid, irrigation) and ensuring high-quality, disease-free seeds.

More largely, CUSMA ensures North America is one of the most food secure regions in the world and the most efficient and economically secure agri-food production and trading region.

A predictable trading environment underpins the integrated North American pulse and special crops market and ensures future growth.

Erosion of this predictability—through tariffs, non-tariff barriers, or weakened dispute resolution—directly threatens the competitiveness of the pulse industry and the broader North American agriculture market.

The importance of market stability, particularly in North America, can’t be stressed enough. It ensures resilient agriculture systems, a vibrant Canadian, US, and Mexican agriculture sector and strong service and ancillary sectors. Already, the ongoing uncertainty swirling around CUSMA’s future, the continued threat of tariffs, and the revocation of established provisions, has negatively impacted innovation, investment, and new business opportunities and has created confusion across long-established supply chains. Here are some examples.

The ongoing threat of tariffs and application questions raises costs, makes it difficult to maintain stable pricing and to execute sales/contracts, as higher prices and unpredictable market conditions reduce customer demand and global competitiveness.

CUSMA supports the movement of Canadian pulse exports to Mexico, often through the United States by rail or truck. Any tariff change in the United States or their treatment of products in transit and under customs control would limit diversification.

The removal of de minimus has limited the options for Canadian companies shipping samples, small lots, or undertaking e-commerce and has created delays and confusion at the Border. What was once relatively seamless cross-border commerce for small and medium enterprises is now complex with added fees and compliance requirements.

CUSMA provides the predictability and stability needed to strengthen a strong North American relationship and to position Canadian pulses and special crops for growth.

CUSMA is a high ambition trade agreement and contains the necessary institutional mechanisms to further collaboration, cooperation and stakeholder engagement related to the North American trade in pulses and special crops. As such, in advance of the 2026 review, Pulse Canada has identified the core strengths of CUSMA that should be maintained.

1. Trilateral scope. As a major buyer of Canadian pulses, Mexico is an integral part of the North American market and maintaining strong trade ties through CUSMA is essential for the long-term growth and competitiveness of Canada’s pulse industry. In addition to CUSMA, the Canada Mexico Action Plan provides the opportunity to strengthen trade ties between Canada and Mexico and to further regulatory cooperation and digitization.
2. Binding, zero-tariff access. Tariffs simply add costs, create inefficiency, and are counter to the spirit of the existing agreement. Agriculture trade, particularly raw commodities like pulses, is a low-margin industry, so even a modest tariff (i.e. 5-10%) has the potential to erode profit margin and to slow trade. Ensuring binding commitments prevent arbitrary or sudden changes in market access preventing the existing environment of unpredictability and uncertainty.
3. Robust SPS Chapter. The chapter includes commitments to science-based decision-making, transparency, and risk-based approaches to protecting plant, animal, and human health. Its objectives, among others, aim to strengthen communication, to reduce unnecessary barriers to trade, and to enhance compatibility of sanitary and phytosanitary measures between Canada, United States and Mexico. Furthermore, it contains mechanisms, such as the SPS committee, to facilitate cooperation among regulatory bodies, the resolution of emerging issues and, is subject to dispute settlement.

Regulatory harmonization of pesticide registration and maximum residue limits (MRLs) and adherence to science-based decision making continue to be needed to facilitate trade and to ensure farmers’ access to innovation. This includes risk-based process assessments to establishing maximum residue levels, including assessment of dietary risk alone, alignment of import tolerances or defaults to a) Codex Alimentarius or b) export market, and increased transparency. While Canada and US regulatory frameworks are generally aligned, Mexico’s framework continues to evolve and to lack clarity. Differences add cost, risk and uncertainty and non-compliances can create problems for future exports.

1. North American Trilateral Technical Working Group on Pesticides. The Working Group, which includes the US and Mexico, is an important forum to foster regulatory alignment and cooperation. Established under NAFTA, it was formed to address trade barriers, cooperate on joint reviews of new pesticides or re-evaluations of existing ones, and to share relevant science and data. The 2026 review provides an opportunity for higher ambition and a trilateral commitment to meaningful progress.
2. Dispute Settlement Function. An effective dispute settlement mechanism is fundamental to ensuring that all parties uphold their commitments and to ensure trust in the Agreement. It provides confidence that disagreements can be addressed impartially and that outcomes will be respected. With the WTO appellate body at an impasse, for agriculture, the mechanism is vital.

Given the importance of CUSMA and the 2026 review, formal industry-government mechanisms should be established to regularly update industry, to share information and for stakeholders to provide guidance as the review discussions evolve.

In conclusion, CUSMA remains the cornerstone of North American agricultural competitiveness. Its clear rules of trade provide the predictability, science-based governance, and market access the pulse and special crop sector requires to thrive. Preserving and reinforcing tariff free access, a robust SPS chapter, and the dispute settlement function, as well as safeguarding the trilateral agreement, will ensure our farmers, processors, and exporters continue to benefit from a stable, prosperous, and resilient North American market.

Sincerely,

Greg Cherewyk
President
Pulse Canada