Washington, D.C. – The Club for Growth Foundation released a new policy report by American Institute for Economic Research Director of Economics and Economic Freedom and Senior Research Fellow Dr. David Hebert, documenting how the Trump Administration’s deregulatory agenda has delivered the most favorable regulatory environment for American manufacturers in decades.
The paper finds that manufacturers pay $29,100 per employee in compliance costs, double the burden of the average U.S. company. Executive Orders 14192 and 14219, combined with the Supreme Court’s Loper Bright decision ending Chevron deference, produced 646 deregulatory actions against just 5 significant new regulations in FY2025, a 129-to-1 ratio. The paper concludes with a reform agenda to make these gains durable, including a Congressional Regulation Office, genuine marginal cost-benefit analysis, and a statutory regulatory budget.
Click here to read the full report from the Club for Growth Foundation and Dr. David Hebert.
KEY POINTS:
The Regulatory Hangover: Four years of Biden-Harris rulemaking added approximately 12,000 rules at a cost of $47,000 per American household in net present value terms. Cost-benefit methodology was skewed toward speculative climate benefits, making virtually any new environmental regulation appear net-positive on paper. The Supreme Court’s Loper Bright decision (2024) ended Chevron deference, removing the legal architecture that allowed agencies to interpret ambiguous statutes as they saw fit for four decades.
Genuine but Incomplete Deregulatory Progress: Executive Order 14192 established a 10-to-1 repeal requirement for new regulations, and Executive Order 14219 directed agencies to rescind rules exceeding their statutory authority. OIRA reports a 129-to-1 ratio of deregulatory to regulatory actions in FY2025, a substantive shift confirmed by George Washington University’s nonpartisan Regulatory Studies Center. But the reported $211.8 billion in savings is concentrated: one rule change, the repeal of FinCEN’s Beneficial Ownership Information requirement, accounts for 60.7% of the total.
States Show What Works and What Doesn’t: Idaho’s Zero-Based Regulation initiative has eliminated 38% of the state’s regulatory code since 2019 and attracted pharmaceutical industry investment without offering incentives to attract them. Michigan spent decades picking winners instead: its flagship MEGA tax-credit program is associated with a net loss of manufacturing jobs per dollar awarded, and its film-incentive program produced just 78 net jobs for $500 million over seven years.
THE REFORM AGENDA:
The paper recommends that Congress establish a Congressional Regulation Office, parallel to the CBO’s role with the federal budget, to independently score the costs and benefits of proposed regulations; require genuine, marginal cost-benefit analysis in agency rulemaking; and codify a statutory regulatory budget that makes the 10-to-1 repeal ratio a permanent structural requirement rather than a single-Administration policy. At the state level, the paper urges lawmakers to wind down targeted tax-credit and subsidy programs, adopt Idaho-style Zero-Based Regulation frameworks, and extend anti-deference statutes to the states that still maintain Chevron-style deference.