President Trump’s America First Trade Policy Memorandum. Many companies breathed a sigh of relief when January 20, 2025 passed without the imposition of tariffs, as candidate Trump had suggested would occur at various points in the campaign. Instead, he issued a trade policy memorandum directing his cabinet agencies to review, assess and recommend remedial measures on a wide range of trade matters, including: the cause of trade deficits, the feasibility of establishing an External Revenue Service, unfair trade practices by other countries, the exchange rate practices of trading partners, the administration of the antidumping and countervailing duty laws, the de minimis exception for imports valued at $800 or less, whether China has acted in accordance with the Phase 1 agreement reached during the first Trump Administration, further modification of the tariffs currently in place on China under the existing Section 301 case, other unreasonable acts, policies or practices of China that may burden U.S. Commerce (potential new Section 301 cases), export controls to maintain, obtain, and enhance our nation’s technological edge and eliminate “loopholes,” the ICTS rule on connected vehicles, the Treasury rule on outbound investment, and more. The memo also instructs the USTR to initiate public consultations related to the review of the USMCA. For most items, the memo requires the agencies to report to the President by April 1, 2025. Overall, the memo suggests a more deliberative approach than some anticipated, while also placing under review nearly every aspect of international trade rules, including newly implemented or nearly implemented rules to which industry has been struggling to adapt and the fate of which is now in question.
President Trump’s First 100 Days 2025