On January 20, 2025, the White House published the America First Trade Policy memorandum, which, at its core, claims to bolster the American economy, workforce, and national security. As government contractors or businesses involved in international trade, the policy, once implemented by the Executive Office, will have various impacts depending on the extent to which your business relies on a foreign supply chain. Below are a few important points that we think could most impact your business. If you want the read the whole policy, use this link.USMCA – Free Trade Agreement
The U.S. Trade Representative (USTR) will seek public comments on the United States-Mexico-Canada Free Trade Agreement, (USMCA) formerly known as NAFTA, to evaluate its domestic impact before the review in July 2026. This is a free trade agreement which means that there are no Tariffs. If you rely on Canada or Mexico to fulfill your Federal procurement needs or to import and sell Canadian or Mexican products, it’s important to pay attention to the upcoming 2026 review. We will keep you informed about the results of the USMCA 2026 review in our future blogs.
WTO – Agreement on Government Procurement
The USTR, in consultation with the Senior Counselor for Trade and Manufacturing will review the World Trade Organization Agreement on Government Procurement (WTO GPA), to assess the volume of Federal procurement covered by EO 13788 (Executive order on Buy American and Hire American). The policy mandates that both the Counselor and USTR provide recommendations ensuring the agreement does not favor foreign nations.
This determination by the administration will be important for contractors. The Trade Agreements Act’s (TAA) designated countries list contains several countries from which you can export end products that are considered compliant with the act for the purposes of TAA. Based on the review, there may be guidance from the administration curtailing your ability to procure from WTO GPA countries.
Furthermore, the TAA thresholds are revised every two years, with the last revision being 2024. Based on the USTR’s determination and discussions with the Senior Counselor for Trade and Manufacturing, in alignment with the White House’s priorities, an increase in the WTO GPA threshold would not be surprising to see in early 2026. FAR 25.403(b) summarizes the current threshold.
Office of the USTR – Request for Comments February 25, 2025
Pursuant to the America First Trade Policy, the Office of the USTR now has a request for comments to assist the USTR in reviewing and identifying unfair trade practices by other countries. While this request is more tuned towards the President’s intention to levy reciprocal tariffs, trade remedies towards unfair trade practices and address trade deficits, there may be more by the USTR to address the other sections mentioned in the Policy.
If you want to discuss how the new administrations trade agenda will impact your business, reach out to the author or to your Centre attorney.
