Trump Administration’s First 100 Days on Agricultural and Food Policy

This issue tracker highlights actions taken by President Donald Trump’s administration during the first 100 days following his January 20, 2025, inauguration that may affect agricultural and/or policy. The goal is to provide an overview of relevant legislation, executive orders, presidential memoranda, and regulatory actions from January 20 to April 30, 2025. Descriptions are not intended to be comprehensive and may simply reference a small portion of a particular item or action, focusing on agriculture and food. Related litigation is not included, although it may certainly reflect or impact agricultural and/or food policy.

Executive Orders

3.19.25 – President Donald Trump issued Executive Order 14239, titled “Achieving Efficiency Through State and Local Preparedness,” which was published in the Federal Register on March 21, 2025. The Executive Order directs the Assistant to the President for National Security Affairs (APNSA) to review President Biden’s National Security Memorandum on Strengthening the Security and Resilience of the United States Food and Agriculture, issued in November 2022. 

3.11.25 – In response to President Donald Trump’s tariffs on certain derivative steel and aluminum product exports from Europe, the European Union (EU) announced countermeasures to protect its interests. These include reinstating previously suspended rebalancing measures from 2018 and 2020 as well as introducing a new package of additional tariffs. The new measures would affect a range of U.S. agricultural products, including poultry, beef, seafood, nuts, eggs, dairy, sugar, and vegetables. According to the European Commission, these countermeasures are expected to take effect in mid-April, following the completion of the adoption process and the entry into force of the implementing act. 

According to a chart from the USDA Economic Research Service, Canada and Mexico are among the United States’ largest suppliers of agricultural products.

2.1.25 – President Donald Trump issued Executive Order 14194, titled “Imposing Duties to Address the Situation at Our Southern Border,” which was published in the Federal Register on February 7, 2025. This Executive Order imposes a 25% tariff on all products imported from Mexico, effective 12:01 am ET on February 4, 2025.

• President Donald Trump issued Executive Order 14198, titled “Progress on the Situation at Our Southern Border,” which was published in the Federal Register on February 10, 2025. This order delays the implementation of the tariff rates, pushing their effective date to March 4, 2025, at 12:01 am ET.

2.1.25 – President Donald Trump issued Executive Order 14193, titled “Imposing Duties to Address the Flow of Illicit Drugs Across Our Northern Border,” which was published in the Federal Register on February 7, 2025. This executive order imposes a 25% tariff on Canadian imported goods, effective at 12:01 am ET on February 4, 2025.

• President Donald Trump issued Executive Order 14197, titled “Progress on the Situation at Our Northern Border,” which was published in the Federal Register on February 10, 2025. This order delays the implementation of the tariff rates, pushing their effective date to March 4, 2025, at 12:01 am ET.

1.20.25 – President Donald Trump issued Executive Order 14156, titled “Declaring a National Energy Emergency,” which was published in the Federal Register on January 29, 2025. This Executive Order states that the EPA Administrator, with the Secretary of Energy’s approval, may issue emergency waivers to allow the year-round sale of E15 gasoline to address supply shortages.

Presidential Memoranda

1.20.25 – President Donald Trump issued the “America First Trade Policy” memorandum, outlining a trade strategy that prioritizes American economic and national security interests. It directs federal agencies to investigate trade deficits, unfair foreign practices, and currency manipulation, and review existing trade agreements, including the USMCA and Economic and Trade Agreement between the United States and China. Agencies must submit their reports by April 2025 with recommendations to improve U.S. trade policies and industrial competitiveness.

1.20.25 – President Donald Trump issued a Presidential Memorandum titled “Regulatory Freeze Pending Review,” requiring all new rules to be reviewed and approved by a department or agency head appointed after January 20, 2025. Pending rules must be withdrawn for review, and their effective dates can be postponed for 60 days. After review, rules with no major issues will move forward while those with significant concerns will require additional evaluation and action.

1.20.25 – President Donald Trump issued a Presidential Memorandum titled “Delivering Emergency Price Relief for American Families and Defeating the Cost-of-Living Crisis.” The memorandum requires all executive departments and agencies to evaluate measures within their authority to provide price relief to Americans, including eliminating climate policies and regulations that drive up food and fuel prices. It requires the Assistant to the President for Economic Policy to submit a report to the President every 30 days on the program of the EO’s implementation.

U.S. Department of Agriculture (USDA)

4.14.25 – The U.S. Department of Agriculture (USDA) ended the Climate-Smart Commodities program started under the Biden administration. After reviewing the projects, the USDA found that “the majority of these projects had sky-high administration fees which in many instances provided less than half of the federal funding directly to farmers.” The USDA introduced a new program named Advancing Markets for Producers (AMP) to replace the previous climate-focused initiative. To qualify, projects must meet three requirements: (1) at least 65% of the awarded funds must go directly to producers, (2) each project must have at least one farmer enrolled by December 31, 2024; and (3) at least one farmer must have received payment by that same date. The announcement clarifies that no new funds will be added; existing funds will be reallocated under these new rules. 

3.31.25 – The U.S. Department of Agriculture (USDA) announced the release of $537 million through the Higher Blends Infrastructure Incentive Program (HBIIP) to fund 543 biofuel projects in 29 states. The goal is to expand access to higher ethanol and biodiesel blends, support rural communities, increase demand for American-grown fuels, and advances President Trump’s “Unleashing American Energy” Initiative.

3.25.25 – The U.S. Department of Agriculture (USDA) announced it will release funding through three rural energy programs–Rural Energy for America Program (REAP), Empowering Rural America (New ERA) and Powering Affordable Clean Energy (PACE) programs–with an option for recipients to revise their project plans within 30 days to align with President Trump’s “Unleashing American Energy” Executive Order. According to the agency, [t]his process gives rural electric providers and small businesses the opportunity to refocus their projects on expanding American energy production while eliminating Biden-era DEIA and climate mandates embedded in previous proposals.” 

3.20.25 – The U.S. Department of Agriculture (USDA) delivered the first progress update on the USDA’s five-pronged strategy to fight highly pathogenic avian influenza (HPAI) and reduce egg prices. USDA Secretary Rollins noted that “[e]gg prices are falling, farmers are getting the relief they need; and we are seeing meaningful progress in the fight against avian flu.” The USDA also reiterated its February 26, 2025, announcement of a $1 billion comprehensive plan to address HPAI, which includes $500 million for improved biosecurity measures, $400 million in direct relief to impacted farmers, and $100 million to support vaccine research, reduce regulatory burdens, and evaluate temporary import strategies. 

3.14.25 – The U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service (APHIS) published in the Federal Register a notice announcing the reopening of the public comment period for the interim rule titled “Payment of Indemnity and Compensation for Highly Pathogenic Avian Influenza,” initially issued in December 2024. The comment period, which was set to close on March 3, 2025, has been extended by an additional 30 days. The interim rule would require commercial poultry farms previously affected by HPAI to first pass a biosecurity inspection before restocking birds in order to be eligible for compensation for any future losses.

2.26.25 – The U.S. Department of Agriculture (USDA) announced in a press release a $1 billion to plan to control the spread of highly pathogenic avian influenza (HPAI), support poultry farmers and make eggs more affordable for consumers. The strategy consists of five major points: (1) “invest in gold-standard biosecurity measures for all U.S. poultry producers;” (2) “increase relief to aid farmers and accelerate repopulation;” (3) “remove unnecessary regulatory burdens on the chicken and egg industry to further innovation and reduce consumer prices;” (4) “explore pathways toward vaccines, therapeutics, and other strategies for protecting egg laying chickens to reduce instances of depopulation;” and (5) “consider temporary import-export options to reduce costs on consumers and evaluate international best practices.”  

2.20.25 – The U.S. Environmental Protection Agency (EPA) published a proposed rule in the Federal Register to reopen and extend the comment period on its December 2024 proposal to revoke most chlorpyrifos residue tolerances (89 FR 99184). According to the EPA, the extension is intended “to give commenters more time to provide input.” The comment period ended on March 24, 2025. The agency also announced plans to issue an amended proposed interim decision for chlorpyrifos for public comment, with a final interim decision expected in 2026. 

2.10.25 – The U.S. Department of Agriculture (USDA) Agricultural Marketing Service (AMS) published a final rule in the Federal Register, delaying the effective date of its previously issued final rule, titled “National Organic Program; Market Development for Mushrooms and Pet Food,” until March 21, 2025. This delay follows the January 20, 2025, Presidential Memorandum, “Regulatory Freeze Pending Review,” giving Department officials more time to review and consider the new regulations. The rule was initially scheduled to become effective on February 21, 2025.

2.3.25 – The U.S. Department of Agriculture (USDA) issued an updated import alert announcing it is resuming cattle and bison imports from Mexico, which had been suspended in November 2024 due to a New World screwworm (NWS) outbreak. Under the updated protocol, all cattle and bison must go through health screenings at designated inspection sites in Mexico before being approved for entry at border crossings in New Mexico and Arizona. However, the import of cattle germplasm, swine, and other specific animal products from Mexico remains banned. Dogs can be imported with a health certificate confirming screwworm inspection and treatment. Horses must follow a treatment and quarantine protocols unless they have spent at least 7 days in a screwworm-free country after leaving Mexico and before entering the United States.    

1.29.25 – The USDA Rural Housing Service (RHS) delayed the implementation of the final rule, “Multifamily Housing Program Update to the Credit Report Process,” published in the Federal Register on December 31, 2024. The rule, initially set to become effective on January 30, 2025, has been postponed until March 31, 2025.

1.28.25 – The USDA Animal and Plant Health Inspection Service (APHIS) delayed the implementation of the final rule, “Horse Protection Amendments,” published in the Federal Register on May 8, 2024. The rule, initially set to become effective on February 1, 2025, has been postponed until April 2, 2025.  

U.S. Environmental Protection Agency (EPA)

3.24.25 – The U.S. Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers published in the Federal Register a proposed rule seeking public feedback on the definition of “waters of the United States.” The notice announces upcoming listening sessions and invites stakeholder to comment on how to implement the definition in light of the Supreme Court’s 2023 decision in Sackett v. EPA. The notice emphasized that “[t]he agencies are committed to learning from the past regulatory approaches—the pre-2015 regulations and guidance, the 2015 Clean Water Rule, the 2020 Navigable Waters Protection Rule, the 2023 Rule, and the Amended 2023 Rule—while engaging with stakeholders before taking further administrative action to provide any additional clarification to agency staff, co-regulators, and the public on specific aspects of the definition of ‘waters of the United States’.”

U.S. Government Accountability Office (GAO)

2.12.25 – The U.S. Government Accountability Office (GAO) issued a decision concluding that the U.S. Department of Agriculture’s (USDA) recording practices for the Supplemental Nutrition Assistance Program (SNAP) did not comply with applicable statutes. The GAO identified two instances of improper recording by the USDA: (1) before September 19, 2023, USDA recorded daily obligations for SNAP based on the amount of benefits issued to households, and (2) after September 19, 2023, USDA “obligated” its FY 2023 one-year appropriation to cover SNAP benefits for FY 2024 that would be given to households in October 2023. According to GAO, SNAP funds should be recorded when they are approved and available for obligation, not when the USDA processes benefit payments. The recorded amount should reflect USDA’s best estimate of benefits owed for FY 2023, rather than the daily issued amounts or benefits for FY 2024. The GAO recommended that the USDA adjust its accounts and charge FY 2024 benefits to the appropriate FY 2024 funds since FY 2023 funds were not meant for them. If there is not enough funding, USDA must report a violation under the Antideficiency Act.