An Early Analysis of President Trump’s Executive Orders
As expected, the first three days of President Trump’s second administration have brought a whirlwind of activity and change. The President issued 42 Executive Orders and proclamations on Monday alone, mandating over 200 actions by federal agencies and rescinding nearly 80 EOs from the Biden administration. Today, we’re highlighting some of the actions that directly impact manufacturers—keep in mind that although the initial barrage is out the door, more EOs are coming.
Energy
- Orders a 30-day review by all federal departments and agencies of regulations and other barriers to the identification and development of domestic energy resources (particularly oil, coal, natural gas, biofuels, critical minerals, nuclear and hydropower);
- Directs the Department of Energy to resume liquefied natural gas export permits, ending the previous administration’s moratorium, and resumes review of LNG export applications;
- Rescinds the “ NEPA Phase 2” rulemaking—the Council on Environmental Quality’s revisions to the National Environmental Policy Act and revokes an executive order by President Carter that gives the CEQ authority to issue binding regulations to other agencies;
- Directs the reconsideration of the legality of regulating greenhouse gas emissions under the Clean Air Act;
- Terminates state emissions waivers that limit the sale of gas-powered vehicles and begins the process of unwinding a suite of vehicle tailpipe regulations from the previous administration;
National Energy Emergency Declaration:
- Authorizes the heads of every federal agency to use emergency powers to facilitate domestic energy development and production;
- Requires a report from the Army Corps of Engineers and other agencies on potential and planned permitting provisions to speed up energy infrastructure permitting under various legislative measures; and
- Requires agencies to use emergency authority under the Endangered Species Act to expedite energy project permitting consultations.
Unleashing Alaska’s Extraordinary Resource Potential:
- Provides for the opening of Alaskan lands to energy exploration and development and promotes Alaskan LNG production.
Putting America First in International Environmental Agreements
- Withdraws the U.S. from the Paris Agreement, a 2015 climate change accord.
Pause on Wind Leasing and Review of Wind Projects
- Blocks lease sales for offshore wind projects and pauses new approvals for leases, permits or loans for on- and offshore wind projects
Trade
- No new tariffs announced.
- Instructs key agencies to begin looking at underlying concerns about unfair or unbalanced trade, specific concerns regarding trade with China and matters related to economic security.
- Three comprehensive reports are due by agencies to the President by April 1. Issues to be investigated include persistent trade deficits; unfair trade practices; currency manipulation; importation of counterfeit products and contraband; China’s compliance with the “Phase One” deal; and review of the U.S. export control system.
- Tasks Commerce Department with assessing unlawful migration and fentanyl flows from Canada, Mexico and China. Those findings are also due April 1.
Regulations
- Imposes a freeze on new and in-process regulations, meaning Biden administration rules that have been proposed but not finalized, finalized but not sent to the Federal Register or sent to the Federal Register but not published.
- Recommends that agencies delay the effective dates of any published-but-not-yet-effective Biden rules by at least 60 days, giving the administration time to decide whether to rescind or revise the rules.
- Reinstates the “one-in-two-out” policy, setting the stage for more reworked and repealed regulations than new rules.
Establishing and Implementing DOGE
- Establishes the Department of Government Efficiency, which will “be dedicated to advancing the president’s 18-month DOGE agenda,” including modernizing technology and software, increasing efficiency and reducing the size of government.
- DOGE will have 90 days to work with the Office of Management and Budget and the Office of Personnel Management on a plan to reduce the size of the federal government’s workforce while a government-wide hiring freeze is ongoing.
Immigration
Enhancing Public Safety in the Interior of the United States
- Reinstated from 2017, this EO prioritizes deportation for individuals convicted, charged or suspected of criminal acts, or otherwise posing a risk to public safety or national security.
- Calls for the hiring of 10,000 immigration officers.
- Encourages federal/state immigration enforcement collaboration.
- Denies federal funds to local jurisdictions that fail to comply with immigration law (aka “sanctuary cities”).
- Among several deportation-related actions, it terminates most categorical parole programs (i.e., programs that allowed individuals without a visa to remain and work in the US because of the situation in their home countries).
Guaranteeing the States Protection Against Invasion
- Declares that the current situation at the southern border qualifies as an “invasion” under Article IV, Section 4 of the Constitution, suspending entry into the United States of aliens “engaged in this invasion” and denies them the right to apply for asylum.
Protecting the United States from Foreign Terrorists and Other Threats
- Directs DHS, State Department and DOJ to report to the President on what countries should have all their nationals barred for any entry into and be deported from the US. This EO also launches a policy process of “enhanced vetting,” to ensure that all “aliens seeking admission to the United States (…) are vetted and screened to the maximum degree possible.”
DE&I
Ending Illegal Discrimination and Restoring Merit-Based Opportunity
- Rescinds executive orders and Presidential memoranda related to federal actions and initiatives to promote diversity and inclusion, including Executive Order 11246—an LBJ-era policy promoting affirmative action in federal contracting.
- Directs the Office of Federal Contract Compliance Programs to immediately cease promoting diversity and requires each agency head to include in every contract or grant award a provision that makes compliance with all applicable federal anti-discrimination laws material to the government’s payment decisions, which includes a certification that the contractor does not operate any DEI programs that violate any applicable Federal anti-discrimination laws.
- Requires each agency to identify up to nine potential civil compliance investigations of publicly traded corporations.
- Requires the Attorney General to submit a report to the Assistant to the President for Domestic Policy containing recommendations for enforcing federal civil-rights laws and taking other appropriate measures to encourage the private sector to end illegal discrimination and preferences, including DEI, within 120 days of the EO (May 20, 2025).
As always, reach out with any thoughts or questions.