President Donald Trump issued an “American First Trade Policy Memorandum” as part of wide-ranging executive actions on Jan. 20, his first day in office. The memorandum calls for a series of reviews of U.S. trade policy and investigations of trade imbalances and unfair trade practices. President Trump’s goal is to “establish[ing] 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 memorandum effectively embraces tariffs as both a negotiating tactic and a revenue source while laying out the initial steps of a process through which the Trump administration could impose new levies. The memorandum suggests that these new tariffs could come through authorities that President Trump utilized in his first term, including Section 232 of the Trade Expansion Act of 1962 and Section 301 of the Trade Act of 1974, as well as untested authorities such as the International Emergency Economic Powers Act (IEEPA).

The memorandum calls for a review of whether China is “acting in accordance” with the trade deal reached during the first Trump administration as well as the effect of current tariffs and “other acts, policies, and practices by the PRC that may be unreasonable or discriminatory …” It also calls for reviews of the de minimis tariff exemption and legislation regarding “Permanent Normal Trade Relations” with China.

President Trump has left the threat of a “global supplemental tariff” on the table, saying during the signing ceremony that he is “not ready for that yet.” Instead, the memorandum calls for an investigation to identify “any unfair trade practices by other countries and recommend appropriate actions to remedy such practices.”

In relation to Canada and Mexico, the memorandum begins the process of preparing for the review of the United States-Mexico-Canada Agreement (USMCA) due in July 2026.

In terms of timing, the memorandum calls for many of the reviews and investigations to be complete by April 1, 2025, implying that that new tariffs on both China and other countries could come in the late spring or early summer. However, in unscripted remarks during the signing ceremony, President Trump said he may impose a 25% tariff on Canadian and Mexican goods on Feb. 1 to combat the influx of illegal immigrants and fentanyl—raising both the prospect that the administration could impose new tariffs before the reviews are complete and that it will use tariffs to pursue broader policy goals. The next day, the President followed up with a similar threat to impose a 10% tariff on imports from China on Feb. 1, also in response to fentanyl shipments.

Beyond tariffs, the memorandum calls for reviews of U.S. export controls, the Biden administration’s executive order (EO) on outbound investment (EO 14105) and the Office of Information and Communication Technology and Services’ (ICTS) recent rulemaking on connected vehicles, including consideration of whether controls on ICTS transactions should be expanded to account for additional connected products.

The memorandum also directs various agencies to consider the feasibility of establishing “an External Revenue Service (ERS) to collect tariffs, duties, and other foreign trade-related revenues.”