In a February 13, 2025 Memorandum, President Donald Trump instructed the Secretary of Commerce and the U.S. Trade Representative, with input from other agencies, to initiate “all necessary actions to investigate the harm to the United States from any non-reciprocal trade arrangements adopted by any trading partners.” Upon completion of this investigation, the president will receive a report “detailing proposed remedies in pursuit of reciprocal trade relations with each trading partner.”

According to the Memorandum, it “is the policy of the United States to reduce our large and persistent annual trade deficit in goods and to address other unfair and unbalanced aspects of our trade with foreign trading partners.” In doing so, President Trump plans to introduce the “Fair and Reciprocal Plan” to counter non-reciprocal arrangements with trading partners “by determining the equivalent of a reciprocal tariff with respect to each foreign trading partner.” Such an approach will be comprehensive in scope, examining non-reciprocal trade relationships with all U.S. trading partners, including: 

  1. tariffs imposed on U.S. products; 
  2. unfair, discriminatory, or extraterritorial taxes imposed by our trading partners on U.S. businesses, workers, and consumers, including a value-added tax; 
  3. costs to U.S. businesses, workers, and consumers arising from nontariff barriers or measures and unfair or harmful acts, policies, or practices, including subsidies, and burdensome regulatory requirements on U.S. businesses operating in other countries; 
  4. policies and practices that cause exchange rates to deviate from their market value to the detriment of Americans; wage suppression; and other mercantilist policies that make U.S. businesses and workers less competitive; and
  5. any other practice that, in the judgment of the U.S. Trade Representative, imposes any unfair limitation on market access or any structural impediment to fair competition with the market economy of the United States. 

The White House provided a Fact Sheet with additional information on this plan.

Background information on President Trump’s concerns over bilateral trade-in-goods deficits is detailed in a May 2019 report issued during the first Trump administration, “The United States Reciprocal Trade Act: Estimated Job & Trade Deficit Effects,” from the White House Office of Trade and Manufacturing Policy, led by Peter Navarro. This earlier report identifies 467,015 tariff lines where the “foreign partner” applies a higher tariff than the United States, 141,736 tariff lines where the United States applies a higher tariff, and 87,319 tariff lines that are reciprocal. According to the analysis, India, China, Vietnam, the European Union, Thailand and Taiwan are the countries with the largest number of tariff lines higher than the United States. 

Photo of David M. Schwartz David M. Schwartz

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping…

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping (AD), countervailing duty (CVD) and safeguard litigation, international trade policy, and cross-border compliance issues affecting goods, services, technology and investments that involve transportation, customs, export controls, economic sanctions, anti-boycott and anti-bribery laws and regulations.

Photo of Dan Ujczo Dan Ujczo

Dan focuses his practice on providing end-to-end counsel across clients’ Canada-United States, North American and global supply chains. This trade counsel includes customs classification and compliance, utilization of preferential trade agreements such as the USMCA, tariff mitigation and exclusions, procurement issues such as…

Dan focuses his practice on providing end-to-end counsel across clients’ Canada-United States, North American and global supply chains. This trade counsel includes customs classification and compliance, utilization of preferential trade agreements such as the USMCA, tariff mitigation and exclusions, procurement issues such as Buy America/Buy American, and anti-dumping/countervailing duty issues. He also advises clients on negotiating transportation agreements, managing trusted trader and related security programs, and addressing issues at ports-of-entry.

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.