

Where is the Trump administration’s trade policy going next? Although President Trump will never be fully predictable, U.S. Trade Representative (USTR) Jamieson Greer is the architect of the underlying strategy, and he has been remarkably clear, consistent and careful, while showing a willingness to be inventive with statutory powers. While legal “creativity” may be a hallmark of this administration, Greer’s methodical approach offers opportunities to plan for costs and advocate for relief.
The Objectives are Clear
During the early months of the administration, frazzled observers asked, “What is he actually trying to do?” They suggested that it’s not possible to achieve all of his stated objectivessimultaneously: domestic protectionism, promotion of manufacturing and investment, leverage for market-access negotiations and collection of tariff revenue.
While it’s true that these goals often conflict, the U.S. economy is complex enough that each objective can be achieved in different ways across different sectors0. For example:
- The Agreements on Reciprocal Trade that have been negotiated to date include market-access elements and other traditional trade objectives, while maintaining varying levels of tariffs.
- The April 2026 update to the steel, aluminum and copper tariffs doubled down on protectionism, while also heeding calls by industry to simplify implementation and reduce the range of derivatives subject to the tariffs.
- On the same day, the announcement of pharmaceutical tariffs was designed to incentivize investment in domestic manufacturing as well as lower prices for drugs in the United States.
As we seek to anticipate the administration’s next moves, USTR Greer has been remarkably clear. Multiple times, he has highlighted the National Trade Estimate, a document that his office produces every year as a guidebook to negotiations. His comments on the U.S.-Mexico-Canada Agreement have outlined specific priorities. These reflect the administration’s goals, as well as public comments and many traditional U.S. trade concerns. Businesses should be aware of USTR’s positions and continue to provide input.
The Tools are Creative
As with other parts of his agenda, President Trump’s trade policy has used existing statutes in new ways. The most notable example is the use of the International Emergency Economic Powers Act (IEEPA) for the initial shock-and-awe stage of tariffs. As we have all seen, this ultimately failed in the Supreme Court but did achieve some negotiating objectives and lay the foundation for ongoing dialogue.
There are three other examples that both set precedent and underline administration objectives:
- On September 5, 2025, the administration unveiled the “Annex III” list of products for which President Trump “may be willing to provide a zero percent reciprocal tariff rate.” In other words, this was a list of “carrots” that could be offered in negotiations with foreign counterparts, and it originated from American importers in the form of exemption requests. Although many were eventually granted to improve affordability, the technique remains.
- On March 12, 2026, USTR launched Section 301 investigations alleging that the governments of 60 economies do not ban imports of goods made with forced labor, which they argue puts American exports at a competitive disadvantage. This is a remarkably efficient method of reimposing tariffs, as it starts with a yes-or-no question: Does each government have a ban? If not, then done.
- On April 2, 2026, the President finally unveiled the national-security tariffs on pharmaceuticals. He is using the Section 232 statute in a novel way, targeting individual companies, with exemptions conditioned on specific commitments related to pricing and domestic manufacturing. Failure to meet milestones could result in an audit and then a 100% tariff.
As we look forward, each of these techniques could be rolled out in other forms, driving opportunities and risks for business. More carrots will be needed to feed future negotiations; additional Section 301 investigations will be rolled out; and individual corporate commitments may come under scrutiny.
And (Some) Execution is Methodical
At the same time, these creative tactics are being deployed within a larger strategy.
It all started with the “everything-everywhere-all-at-once” phase, kicking into high gear on “Liberation Day” (April 2, 2025). It was commonly described as chaotic, with high-level negotiations resulting in vague commitments.
But then, talks became more focused, countries were prioritized, and negotiators got into the nitty gritty. The documents released publicly have been progressively more detailed; first frameworks and then signed agreements. Deals addressed longstanding U.S. complaints that have been outlined year after year in the National Trade Estimate.
USTR is currently busy working to replace the fallen IEEPA tariffs, but negotiations and sequenced implementation are likely to continue through the end of the president’s term, so public feedback remains important.
Implications for Business
Taken together, these dynamics suggest four conclusions for multinational companies:
- Advocacy matters. USTR and Commerce are calibrating impact and are willing to make some adjustments, as seen with the steel, aluminum and copper tariffs. They are also absorbing industry input to develop detailed negotiating demands and industry exemption requests as potential carrots.
- The objectives are firm. Industry feedback will only be used if it aligns with administration priorities.
- Watch trade actions across sectors. Each creative policy application should be viewed as a pilot for broader use.
- There’s more to be done. While the tariff shock-and-awe stage has largely concluded, trade remains a top administration priority.
For companies, this creates both risk and opportunity. Engagement through formal comments, industry associations, advocacy campaigns and direct dialogue can influence outcomes. However, that engagement should be carefully calibrated, grounded in a clear understanding of the administration’s objectives and the broader political context.
In a trade environment defined by unconventional tactics, the ability to anticipate where policy is heading and engage strategically will be a critical differentiator.

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