President Trump, on January 31, 2025, issued Executive Order 14192, “Unleashing Prosperity Through Deregulation.” This has been referred to as President Trump’s “ten-to-one deregulation initiative” that he spoke about when he was campaigning. If this initiative seems familiar, it may be because you remember Executive Order 13771, “Reducing Regulation and Controlling Regulatory Costs,” issued on February 3, 2017, by President Trump in his first term. That Executive Order called for a two-to-one repeal of regulations.

Section 3 of Executive Order 14192 requires that “whenever an executive department or agency (agency) publicly proposes for notice and comment or otherwise promulgates a new regulation, it shall identify at least 10 existing regulations to be repealed.” For Fiscal Year 2025, the heads of all agencies are directed to ensure that the total incremental cost of all new regulations, including repealed ones, shall be “significantly less than zero” as determined by the Director of the Office of Management and Budget.

It is one thing to identify regulations to be repealed. It is another thing to repeal existing regulations. The Congressional Review Act (CRA) is one way to eliminate regulations, but that requires legislation and has limits. According to the Congressional Research Service, the CRA has been used to overturn a total of 20 rules: one in the 107th Congress (2001-2002), 16 in the 115th Congress (2017-2018), and three in the 117th Congress (2021-2022). The other way is to follow the Administrative Procedure Act (APA), which is a more time-consuming option that does not lend itself to the “make immediate change” actions of the new Administration.

A cynic would say that the ten-to-one Executive Order is more about making headlines and inviting the perception of action because that is what people will remember. President Trump campaigned on reducing regulatory burdens and the reach of government, so actions such as this should not be surprising to anyone.

It remains to be seen how many significant regulations will be targeted for repeal and eventually be repealed by the Trump Administration. It will be interesting to watch how businesses in highly regulated industries, including the chemical manufacturing industry, could benefit or be challenged by these potential regulatory actions.