Trump Trade Policy, Year Two

Felicia Pullam

During the first year of the second Donald Trump administration, trade policy shifts affected every business, and commentators applied a full range of superlatives to describe it. The most common was “unprecedented.” Last year was hard to forget; many of us were asking ourselves the same question: how should we respond?

Inside most companies, customs and other operational colleagues were slammed, as they labored to understand the immediate cost implications, manage compliance requirements and reconfigure mission-critical supply chains. Internal coordination—never simple in large organizations—became even more strained, impacting message development and advocacy. In Washington, lobbyists were immobilized as they assessed the risks of engagement, while more than a few commentators proclaimed it futile without “Mar-a-Lago-level access.”

Now that we’re a few months into the second year, what’s changed and what’s next?

From paralysis to selective engagement

When President Trump announced new tariffs on “Liberation Day” in April 2025, only a narrow set of voices spoke within the first week. High-profile figures in the investment community, less constrained by consumer sentiment, were among the few able to weigh in.

Since then, the environment has matured. Trade policy is still uncertain, but the changes are slower-moving and somewhat easier to predict. There are indications that leaders within the administration are receptive to stakeholder input. Experienced personnel at the U.S. Department of Commerce and the Office of the United States Trade Representative are actively analyzing feedback from both industry and civil society.

Thousands of companies have filed lawsuits in tariff cases, with little public evidence of retribution. Others have submitted public comments on tariffs and other trade policy priorities during formal processes led by Commerce and USTR.

This evolution creates a more nuanced communications environment. Advocacy, comments and other forms of messaging can be worthwhile but are also not without risk. Partisans are taking note and election-year politics are heating up.

Emerging risks for communications around trade

Companies must continue to account for multiple audiences within the United States: Sincere policymakers, political operatives and a wide variety of other stakeholders, including frustrated consumers, many of whom are wondering when they’ll get their tariff refunds. And beyond U.S. borders, even more stakeholders are becoming increasingly disillusioned.

Several risk vectors have become more pronounced:

Policy adaptation without strategic retreat. In April, the Trump administration rolled back some tariffs on products made with steel and aluminum, while also simplifying the remaining tariffs in response to widespread industry complaints.

Although their refinements showed flexibility, they also maintained a strong commitment to the original goal of protecting domestic metal production. While some imports are no longer subject to these tariffs and some face a lower rate, others are still subject to a 50 percent duty. The administration simplified the paperwork by applying the tariff to the full cost of the good, rather than the value of the metal content. To be sure, the math is easier, but the final tariff amount is higher.

There are two takeaways for communicators. First, engagement can shape outcomes … but not always predictably. Second, you must be aware of the Trump administration’s steadfast objectives and communicate with that in mind.

Company-specific targeting and creative tactics. Also in April, the president announced the long-awaited Section 232 actions on pharmaceuticals, including a 100 percent duty on branded drugs. Individual companies will receive exemptions by making deals with the administration on pricing and domestic manufacturing. Milestones will be established and monitored, potentially subject to external audits. This administration is using a national-security tariff authority in a completely novel way: to control the actions of individual companies.

This raises a few questions. First, is this a model for other industries? Second, is this legal and does that matter? The optics of suing the Trump administration instead of investing in American manufacturing are not good.

So, what does this mean for communicators? Continue to take care when talking about investment plans externally. The administration is tracking and highlighting announcements, with an eye towards accountability.

A renewed focus on forced labor. In March, the Trump administration announced two Section 301 investigations, with the intention of using the results to levy new tariffs to replace those struck down by the Supreme Court. One investigation targets 60 economies to determine whether governments have banned the import of goods made with forced labor into their respective territories, claiming that not doing so disadvantages American exporters.

There’s substantial confusion around this investigation. It’s a yes-or-no question: Either a country has a ban or it doesn’t. Only Mexico, Canada and the European Union have bans, so for them, the next question is whether they are effectively enforced. But, since forced labor has plagued humanity for millennia, enforcement is notoriously difficult.

There are few things worse than forced labor. This is an area where companies should proceed with extreme caution in public commentary. Missteps carry not only regulatory consequences but also significant reputational exposure. Instead, managers should redouble efforts to ensure that their own supply chains are clean and consider whether lessons learned could be helpful as governments seek to improve enforcement.

U.S. midterm elections and continuing geopolitical instability. Layered onto these dynamics is the reality of election-cycle politics, along with the unpredictability of war.

Trade policy is increasingly a political instrument, and companies can find themselves drawn into narratives that serve broader campaign objectives. Even neutral or technical positions may be reframed for political effect, creating headline risk.

Further, companies must prepare for a policy landscape that could shift again. Maintaining relationships and credibility across both sides of the aisle is essential. Communications strategies should be vetted not only for immediate impact but also for their durability under different political scenarios.

The strategic upside of engagement

Despite these risks, there are tangible benefits to participation.

As USTR Greer continues to lead bilateral negotiations, likely through the end of President Trump’s term, he is seeking foreign concessions on trade barriers that have eluded prior administrations. Corporate input—whether through formal comments, quiet diplomacy or coordinated advocacy—is shaping U.S. negotiating priorities.

The administration has been taking a phased approach to negotiations. In 2025, President Trump focused on the highest commitments, and each phase has become progressively more detailed. Within this framework, tariffs serve as “sticks,” while exemptions and tariff reductions function as “carrots.”

This means that new carrots will be needed over time: exemptions or lowered rates could come into play. Firms that can effectively articulate their case—grounded in economic impact, supply chain realities or national interest—have a pathway to mitigate exposure. For communications teams, this will be an ongoing process.

The importance of cross-functional, cross-border alignment

The complexity of this environment underscores the need for tighter integration across corporate functions.

Public affairs, communications, legal, compliance and business units must operate from a shared understanding of both policy risk and messaging strategy. Misalignment—particularly across geographies—can create vulnerabilities.

Internationally, companies face the added challenge of message consistency. Statements made in the United States may conflict with positioning in foreign markets. Managing these tensions requires deliberate planning and disciplined execution.

Year two of Trump’s trade policy presents a more flexible, but more complex, communications environment. The opportunity to influence outcomes is real. So is the risk.

For communications professionals, success will depend on disciplined strategy, cross-functional coordination and a clear-eyed assessment of when—and how—to engage.

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Felicia Pullam is Head of APCO Worldwide’s Center for Trade, Investment and Market Access.