The U.S. International Trade Commission published a Federal Register notice on April 10, 2026, opening a 60-day public comment period for the USMCA Automotive Rules of Origin Motor Vehicle Producer Questionnaire under Investigation No. 332-608. The questionnaire will collect compliance data from an estimated 25 North American motor vehicle producers with U.S. production operations, with responses scheduled for collection in 2026.

This data collection supports the third of five biennial reports mandated by 19 U.S.C. 4532(g)(2), with the 2027 report due to the President, House Committee on Ways and Means, and Senate Committee on Finance no later than July 1, 2027. The USITC completed the second report on July 1, 2025, and three additional reports remain scheduled for 2029 and 2031 delivery dates.

Questionnaire Scope and Burden Estimates

The USITC estimates each of the 25 targeted respondents will require approximately 25 hours to complete the questionnaire. The agency will distribute the form via email with individualized access codes linking to an online submission portal. All responses will be treated as confidential business information and will not be disclosed in a manner revealing individual company operations.

The questionnaire targets data on USMCA automotive rules of origin impacts across three dimensions specified in the Act: effects on the U.S. economy, effects on U.S. competitiveness, and relevancy of existing ROOs given recent technology changes in the automotive sector.

Investigation Timeline: Investigation 332-608 was instituted on February 11, 2026, with the notice of investigation published in the Federal Register on February 23, 2026 (91 FR 8521) and corrected on February 26, 2026 (91 FR 9640).

Compliance Engineering Implications

For trade compliance teams managing USMCA origin calculations, this ongoing investigation signals continued federal scrutiny of automotive ROO methodology through at least 2031. Vehicle producers calculating regional value content (RVC) and labor value content (LVC) thresholds should anticipate sustained reporting requirements tied to these biennial reviews.

Comment Deadline: Public comments on the draft questionnaire elements, burden estimates, and collection methodology must reach the Commission within 60 days of the April 10, 2026 publication date. Submit via email to the project team or contact Conor Hargrove at 202-708-5409.

Systems interfacing with HTS classification data for automotive parts face particular exposure here. The USITC's evaluation of ROO relevancy amid technology changes—including electric vehicle components and advanced manufacturing inputs—could inform future tariff schedule modifications affecting origin determination logic.

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The Commission accepts comments on five categories: questionnaire elements, necessity of the proposed collection, accuracy of burden estimates, methods to enhance data quality and clarity, and approaches to minimize respondent burden. All investigation materials are accessible via the Commission's electronic docket (EDIS) at https://edis.usitc.gov.