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First 100 Days: Upcoming Regulatory Signals for Industrial Manufacturing & Auto

Indicators of potential regulatory shifts to agency objectives and regulatory focus

Columns

乐鱼(Leyu)体育官网 Regulatory Insights

  • 鈥楢merica First鈥� Agenda: Expect continued/expanded use of tariffs, sanctions and/or bans (e.g., China) inclusive of sector-specific and tech-related products and services.
  • Regulatory & Inspection Pullback: Expect a general regulatory, inspection and enforcement pullback, inclusive of labor/workplace and anti-competition.
  • State Divergence: Expect increasing federal and state regulatory divergence (e.g., workplace safety, climate-related).

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February 2025

Regulatory changes to the industrial manufacturing and auto sectors are largely expected to be in areas related to the 鈥淎merica First鈥� and 鈥渄e-regulatory鈥� agendas. Specific actions by the Administration in areas like tariffs, immigration, sanctions and bans are expected to continue to be dynamic for the coming years.

Even with this iterative policy background, numerous regulatory signals are anticipated both in terms of:

  1. Agency Objectives, including regulatory pullback and investigations/enforcement shifts
  2. Regulatory Focus, including national security and competition

See also 乐鱼(Leyu)体育官网 Economic Compass: Breaking Up Is Hard To Do: Tariffs & Trade Wars, here.

1.听听Agency Objectives

Changes to the industrial manufacturing and auto regulatory, inspection and enforcement agencies are likely to affect certain agency objectives, including:

Signals

Description/Examples

Source

鈥淎merica First鈥� Initiative

Implementation of 鈥淎merica First Priorities鈥�

Ongoing implementation of the 鈥淎merica First Trade Policy鈥�, including tariffs and other measures or policies, trade policies/practices/agreements, and export/import controls on sector-specific, country specific, and/or tech related levels

White House, and

Regulatory Pullback

Fewer new regulations, consistent with the Executive Order on deregulation

Reassessment of recent final/proposed rules, in keeping with the 鈥渞egulatory freeze鈥� Executive Order (e.g., OSHA Heat Safety Rule, Walkaround Rule; DOC Connected Vehicles Rule)

Revisions/recissions of regulations (e.g., EPA, NHTSA) in areas such as GHG, fuel economy, and IRA funding (e.g., EV consumer lease credit, some infrastructure)

Potential reconsideration of previously granted waivers (e.g., CA)

Inspection & Enforcement Shift

Implementation of Executive Order pausing investigations and enforcement of the FCPA and directing review/revision of the related guidelines and policies

Implementation of DOJ Memo re-prioritizing enforcement focus of FCPA to foreign bribery that facilitates the criminal operations of Cartels and Transnational Criminal Organizations

Potential shift to 鈥榚vidence of effects鈥� of anti-competition and a focus on procedural requirements to issue administrative complaint with a 鈥渞eason to believe鈥� (FTC Act Section 5)

Potential for fewer (and longer duration) workplace inspections, due to likely federal government workforce reductions

Potential for lessening to DOL/OSHA whistleblower investigations (and given regulatory 鈥榩ause鈥�)

State Activity

State laws expected to be increasingly divergent from federal, particularly given evolving regulatory pullback (e.g., workplace/labor provisions, GHG standards)

2.听听Regulatory Focus

To drive forth the Administration鈥檚 鈥淎merica First鈥� and 鈥榙e-regulatory鈥� agenda, potential changes in key regulatory areas for industrial manufacturing and auto may include a particular focus on and changes to:

Signals

Description/Examples

Source

National Security

Decreased dependence on other countries, resulting in likely continued/expanded use of tariffs, sanctions and/or bans (e.g., China) and re-evaluation of trade policies and agreements inclusive of sector-specific, county-specific and tech-related

Identified areas may include/expand adjustments to: investment/import policies (e.g., inputs (e.g., steel, aluminum), technologies (e.g., IP, connected products)); export policies (e.g., preventing circumvention of controls through supply chains); anti-dumping/countervailing duty laws; trade 鈥渂alance鈥� and reciprocity

Competition

Re-consideration to 鈥渆arly termination鈥� waiting periods on deals, as well as options (divestitures, etc.) and factors used in competition analysis

Potential re-consideration of DOJ/FTC Merger Guidelines, including market-share and concentration thresholds for finding transactions anti-competitive

Dive into our thinking:

First 100 Days: Upcoming Regulatory Signals 鈥� Industrial Manufacturing & Auto

Indicators of potential regulatory shifts to agency objectives and regulatory focus

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