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MemoMemorandumTrump 47 · R

Presidential Memorandum

America First Trade Policy

This January 20, 2025 memorandum directs multiple Cabinet members and agency heads to conduct broad reviews and investigations across trade policy, with reports due by April 1, 2025 (and one by April 30, 2025). It covers trade deficits, tariff structures, currency manipulation, USMCA renegotiation preparation, China trade practices, steel/aluminum national security measures, export controls, de minimis exemption reform, outbound investment rules, and procurement policy—but does not itself impose any tariffs or binding policy changes.

Federal Register Open PDF 90 FR 8471

Impact dates

  1. 50d ago

    USMCA review (referenced as July 2026 review; specific date not stated)

  2. Report by OMB Director on foreign subsidies in federal procurement (Sec. 4(f))

  3. Unified reports coordinated by Secretary of Commerce (Sec. 2(a), 2(h), 3(d), 3(e), 4(a), 4(b), 4(c), 4(d), 4(g))

  4. Unified reports coordinated by USTR (Sec. 2(c), 2(d), 2(f), 2(g), 2(k), 3(a), 3(b), 3(c))

Market exposure

Policy exposure mapping — not investment advice. Illustrative public companies are incomplete and not recommendations.

Sectors

Steel & aluminumAutosSemiconductorsTechnology & softwarePharmaAgriculture

Mechanisms

TariffQuotaSubsidy / incentiveProcurementLicensing

Role pressure

  • ProtectiveDomestic producer — Steel/aluminum exclusion review, potential global supplemental tariff, AD/CVD enforcement changes, and Buy American procurement preferences all favor domestic manufacturing
  • AdverseImporter — Global supplemental tariff under consideration, de minimis exemption review threatens low-value imports, stricter AD/CVD verification procedures likely
  • MixedDownstream manufacturer — Steel/aluminum users face potential restriction of exclusions; China supply chain tariffs and circumvention enforcement raise input costs but domestic competitors also face pressure
  • AdverseTrading-partner exporter — Currency manipulation designation, potential USMCA changes, and bilateral sectoral negotiations create uncertainty for CN, MX, CA, and other major exporters

Geographies

USCNMXCAEUJPKRTWVNOTHER

Exposure dates

  • — Unified reports coordinated by USTR (Sec. 2(c), 2(d), 2(f), 2(g), 2(k), 3(a), 3(b), 3(c))
  • — Report by OMB Director on foreign subsidies in federal procurement (Sec. 4(f))

Illustrative public companies

Curated watchlist matches by sector/role — incomplete; not a recommendation.

AAAlcoaGOOGLAlphabetAAPLAppleADMArcher Daniels MidlandAVGOBroadcomBGBungeCATCaterpillarCENXCentury AluminumCLFCleveland-CliffsCTVACortevaLLYEli LillyFFordGMGeneral MotorsHYMTFHyundai MotorINTCIntelQQQInvesco QQQ TrustJNJJohnson & JohnsonMRKMerckMETAMeta PlatformsMUMicron TechnologyMSFTMicrosoftNVSNovartisNUENucorNVDANVIDIA

Confidence: medium · Policy alerts

Key directives

  • Investigate causes of trade deficits and recommend global supplemental tariff or other policies (Sec. 2(a))
  • Investigate feasibility of establishing External Revenue Service (Sec. 2(b))
  • Review unfair trade practices and recommend actions under multiple statutory authorities (Sec. 2(c))
  • Commence USMCA public consultation for July 2026 review (Sec. 2(d))
  • Assess currency manipulation by major trading partners (Sec. 2(e))
  • Review de minimis exemption ($800 or less) for revenue loss and fentanyl/contraband risks (Sec. 2(i))
  • Review China Phase One agreement compliance; recommend tariffs if needed (Sec. 3(a))
  • Assess additional Section 301 tariffs on China, especially supply chains and circumvention (Sec. 3(b))
  • Review steel/aluminum exclusion effectiveness for national security (Sec. 4(b))
  • Review export controls and identify loopholes for strategic rivals (Sec. 4(c))
  • Review connected vehicle ICTS rulemaking; consider expanded controls (Sec. 4(d))
  • Review whether to modify/rescind EO 14105 outbound investment rules (Sec. 4(e))

Who is ordered

Timeline

Immediate

  • Memorandum issued; agency heads directed to begin reviews and investigations

Near term (90d)

  • Unified reports due April 1, 2025 (most sections)
  • OMB report due April 30, 2025
  • USTR to commence USMCA public consultation process

Long term

  • Potential tariff imposition based on recommendations
  • Possible establishment of External Revenue Service
  • USMCA review by July 2026
  • Potential modifications to outbound investment program
  • Possible expansion of ICTS controls on connected products

Risks & tensions

  • Actual tariff imposition depends on future presidential action post-reports; this memo creates no immediate trade barriers
  • Multiple statutory authorities cited suggest administration is preserving maximum flexibility for unilateral action
  • De minimis review threatens e-commerce supply chains but no immediate change to $800 threshold
  • EO 14105 (Biden-era outbound investment rule) explicitly flagged for potential rescission—clear prior-admin reversal signal
  • Currency manipulation designation could escalate bilateral tensions with major trading partners
  • USMCA consultation timing (2025) ahead of 2026 review suggests potential renegotiation pressure on Canada/Mexico
  • Vague reference to 'unlawful migration and fentanyl flows' as basis for trade measures links immigration and trade policy
Presidential Memorandum: America First Trade Policy · Executive Orders