America First Trade Policy:  The White House’s Trade and Economic Agenda in Motion

Since his election victory on November 5, 2024, the international trade community has postulated about US President Donald Trump’s trade policies, comparing the policies of his 2016 term with various official statements from his campaign and with the statements he has made on his social media. The memorandum released by the White House on very day of his inauguration, however, puts to rest much idle speculation on the general outline of the Trump Administration’s forthcoming trade policy.

While there is still a degree of uncertainty (at the time of writing) about the concrete plans for the key tariffs Trump has threatened to levy (against Canada, Mexico, China, and BRICS nations to name a few), the White House’s America First Trade Policy memorandum, published January 20, 2025 and addressed to – among others – the Secretary of the Treasury, the Secretary of Commerce, and the US Trade Representative, prescribes analysis and reports from which to base a progressive, revisionary trade policy with major consequences for the international trade community, all under the mission statement of “establishing a robust and reinvigorated trade policy that promotes investment and productivity, enhances our Nation’s industrial and technological advantages, defends our economic and national security, and — above all — benefits American workers, manufacturers, farmers, ranchers, entrepreneurs, and businesses.”

The contents of the memorandum are extensive, and merit a thorough examination by all stakeholders in US international trade, as well as by US trading partners whose relationships will be reexamined by the Trump Administration over the next 10 weeks: The memorandum instructs its addressees to provide the results of their analysis to the US President by April 1, 2025. Taken together, the memorandum is a thoroughgoing audit of current US trade policy. Examining even only a few of the major prescriptions it directs, we can see the potential for major changes impacting international trade in general and US businesses in particular in the coming years. Here are some of the significant investigations ordered by the memorandum, arranged by their addressees:

Secretary of Commerce

• Investigate the cause of US’s annual trade deficit
• Review policies and regulations regarding antidumping and countervailing duty laws, as well as the procedures for conducting verifications, and consider modifications to the procedures as appropriate
• With the US Trade Representative (USTR), assess legislative proposals regarding Permanent Normal Trade Relations with the People’s Republic of China (PRC) and make recommendations regarding any proposed changes those proposals.
• Assess the status of US intellectual property rights such as patents, copyrights, and trademarks conferred upon PRC persons, and shall make recommendations to ensure reciprocal and balanced treatment of intellectual property rights with the PRC.

US Trade Representative (USTR)

• Review any unfair trade practices by other countries and recommend remedies
• Commence public consultation process for USMCA in preparation for the trilateral review in July of 2026
• Assess the impact of USMCA on American workers and businesses and make recommendations regarding the US’s continued participation in USMCA 
• Identify countries with which the US can negotiate trade agreements to obtain export market access for American businesses 
• Review the Economic and Trade Agreement between the US and China to “determine whether the PRC is acting in accordance with this agreement and…recommend appropriate actions to be taken based upon the findings of this review, up to and including the imposition of tariffs or other measures as needed.”
• Assess Section 301 tariff against China and consider modifications as needed, with respect to industrial supply chains and circumvention through third countries, and including an updated estimate of the costs imposed by any identified unfair trade practices
• Identify any other acts, policies, and practices by the PRC that burden or restrict US commerce and make recommendations for appropriate actions

Secretary of Treasury

• Review policies and practices with respect to foreign currency exchange with the USD and recommend measures to counter currency manipulation, as well as identify any countries believed to be designated currency manipulators

Sec of Treasury, of Commerce, of Homeland Security, and Senior Counselor for Trade and Manufacturing, in consultation with the USTR

• Assess the loss of tariff revenues and the risks of importing counterfeit products and contraband (e.g., fentanyl) that result from shipments imported under the de minimus administrative exemption and recommend modifications as warranted “by preventing unlawful importations”

The Assistant to the President for Economic Policy, in consultation with the Sec of Commerce, the USTR, and the Senior Counselor for Trade and Manufacturing

• Review and assess the effectiveness import adjustment measures on steel and aluminum

The Secretary of Commerce and the Secretary of Homeland Security

• Assess the unlawful migration and fentanyl flows from Canada, Mexico, the PRC, and recommend appropriate trade and national security measures

Conclusions

The sum of the directives in the America First Trade Policy memorandum prescribe analysis and reporting from the major trade offices of the executive administration necessary to make changes to US trade policy that are both precise and sweeping. Many of them speak directly to claims that Trump and his campaign affirmed prior to his inauguration, and most of them stand to have a direct impact on the supply chains and import costs of US businesses, notably:

• Multiple potential sanctions on China, including but not limited to additional tariffs
• Possible revisions to Section 301 and 232 tariffs (China and Steel and Aluminum tariffs)
• Possible tariffs on Canada and Mexico, and the revision of USMCA
• Changes to antidumping and countervailing regulations and cases
• Reduction of de minimus administrative exemption for imports under $800
• Import and export restrictions associated with military technology  and intellectual property

The questions that the America First Trade Policy memorandum asks are suggestive of the answers they obtain to: increased regulations, sanctions, and tariffs on multiple fronts. Notwithstanding further developments announced from the white house, the trade community should use the next 10 weeks to audit their own supply chains and analyze the business impact they could sustain from the US’s economic policy in the coming years.

Allyn International’s service suite includes consultation on current and developing issues in the US trade community. Reach Allyn Here for a consultation or, contact us sales@allynintl.com or 239-489-9900.

Contributor: Andrew Dosher

---

About Allyn International 

Allyn International is dedicated to providing high quality, customer centric services and solutions for the global marketplace. Allyn's core products include transportation management, logistics sourcing, freight forwarding, supply chain consulting, tax management and global trade compliance.  Allyn clients range from small local businesses to Fortune 500 firms. Allyn conducts business in more than 20 languages and has extensive experience in both developed and emerging markets. Highly trained experts are positioned throughout North America, Europe, and Asia. Allyn’s regional headquarters are strategically located in Fort Myers, Florida, U.S.A., Shanghai, P.R. China and Prague, Czech Republic. For more information, visit www.allynintl.com.