Trump 2.0 Has Signed 16 Congressional Review Act Resolutions Of Disapproval

In recent roundups of the Trump-era administrative state and its “Unrules,” we’ve noted that the Trump administration is on track (so far) to issue the lowest annual tally of rules and regulations since record-keeping began in the 1970s.

United States Department Of Government Efficiency concept cutting US bureaucratic red tape and reducing American bureaucracy as a USA political policy to cut wasteful spending.

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While a number of Trump rules take the form of recissions, rollbacks, delays and relaxation of enforcement, it is the congressional “Resolutions of Disapproval” of late-term Biden rules that are getting much of the attention. Rooted in the Congressional Review Act of 1996, these allow Congress and a new president to overturn certain rules issued late in a predecessor’s term.

To some extent the attention that CRA’s get makes makes sense, as these disapprovals tend to zero in on some of the most prominent recent regulatory activity. In the current setting, it is Biden’s aggressive and even punitive green agenda getting upended, not just by Congress and its CRAs, but prominently by the Department of Energy and the Environmental Protection Agency (as a flurry of tweets from EPA Administrator Lee Zeldin attests in the latter case).

Before Trump 1.0, there had been only one resolution of disapproval signed into law -targeting Department of Labor rulemaking on repetitive-motion injuries. But then in a rapid 2017-18 change of pace, the Trump administration overturned 16 Obama rules.

Turnabout was not unexpected, so the Biden era brought three reversals of Trump rules (notably on relaxation of emission standards and bank lending), as part of what proved to be Biden’s wholesale rejection of regulatory streamlining as such in favor of what his administration dubbed “whole-of-government” progressive interventions.

Here we are in 2025. So far in Trump 2.0 there have been 16 resolutions of disapproval of Biden-era rules (the most recent signed into law on June 20, as compiled below).

Of dozens of candidates for potential overturn by CRA resolution of disapproval (I did an inventory in this column late last year) Congress did wind up getting rid of some of the most noteworthy.

That comes with a big caveat, however. While the CRA does get used to eliminate some of the most significant, headline-grabbing and prominent regulations, the CRA cannot fundamentally roll back the administrative state.

Remember; the CRA has been with us since 1996. A pace of a couple dozen rule eliminations per generation – however large or costly and worthy of revocation they may be individually – is a slog that just won’t do to preserve limited government over the long term.

Consider: betwwen 1976 (when federal agency rules first started getting counted in the Federal Register) and year-end 2024, 220,813 final rules were finalized. So far this year, another 1,560 rules have been issued (granted, a sizable number of them the recissions and relaxations noted) for a total of 222,373. A few dozen CRAs makes just a dent.

Not only that, as CEI’s work on agency guidance documents, policy statements memoranda and other forms of regulatory dark matter attests, conventional notice-and-comment regulation increasingly comes nowhere close to capturing government intervention in the economy. That intervention includes the likes of antitrust regulation (which I like to refer to as the Original Sin of the administrative state, although even it has forebears); tariffs; and perhaps most distressingly, regulatory laundering via the procurement/contracting behemoth and subsidies, grants and public-private partnerships. Topping the list and responsible for all the rest is congressional disregard of enumerated powers, its unwillingness to leave any corner of economic or social life alone and the collapse of federalism.

But still, during White House transitions, the CRA resolutions are the splashiest and most headline grabbing, and they do matter a lot for planning and strategy.

There’s also an interesting twist to all this in 2025. So far, there have been are “only” 31 public laws enacted in the 119^th Congress. But half of them (16, as noted) have been CRA resolutions of disapproval.

It’s kind of funny to think that half of 2025’s laws are Biden rule-killers.

We’ve long needed legislators willing to come to DC, not to “get things done” and be otherwise meddlesome, but to get things undone. The year 2025 has served as an example of how to go about that.

Among prominent CRAs in 2025 are the Department of Energy’s conservation standards (“We now have the technology available to eliminate efficiency!” our CEI founder Fred Smith would joke about wrongheaded federal policies). EPA is dominant of course, along with some finance rules. What follows is the to-date compilation of rules and the public law overturning them. As the year progresses, these may be tracked at the Government Accountability Office’s landing page for Congressional Review Act goings-on:

1. Bureau of Ocean Energy Management, “Protection of Marine Archaeological Resources” (Federal Register, vol. 89, p. 71,160 (Sept. 3, 2024). Pub. L. 119-3 (Mar. 14, 2025).
2. Environmental Protection Agency, “Waste Emissions Charge for Petroleum and Natural Gas Systems: Procedures for Facilitating Compliance, Including Netting and Exemptions” (Federal Register, vol. 89, p. 91,094 (Nov. 18, 2024). Pub. L. 119-2 (Mar. 14, 2025).
3. Internal Revenue Service, “Gross Proceeds Reporting by Brokers That Regularly Provide Services Effectuating Digital Asset Sales” (Federal Register, vol. 89, p. 106,928 (Dec. 30, 2024). Pub. L. 119-5 (Apr. 10, 2025).
4. Department of Energy, “Energy Conservation Program: Energy Conservation Standards for Commercial Refrigerators, Freezers, and Refrigerator-Freezers” (Federal Register, vol. 90, p. 7,464 (Jan. 21, 2025). Pub. L. 119-9 (May 9, 2025).
5. Department of Energy, “Energy Conservation Program for Appliance Standards: Certification Requirements, Legal Requirements, and Enforcement Provisions for Certain Consumer Products and Commercial Equipment” (Federal Register, vol. 89, p. 81,994 (Oct. 9, 2024). Pub. L. 119-8 (May 9, 2025).
6. Department of Energy, “Energy Conservation Program: Energy Conservation Standards for Walk-In Coolers and Walk-In Freezers” (Federal Register, vol. 89, p. 104,616 (Dec. 23, 2024). Pub. L. 119-7 (May 9, 2025).
7. Department of Energy, “Energy Conservation Program: Energy Conservation Standards for Consumer Gas-fired Instantaneous Water Heaters” (Federal Register, vol. 89, p. 105,188 (Dec. 26, 2024). Pub. L. 119-6 (May 9, 2025).
8. Consumer Financial Protection Bureau, “Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications” (Federal Register, vol. 89, p. 99,582 (Dec. 10, 2024). Pub. L. 119-11 (May 9, 2025).
9. Consumer Financial Protection Bureau, “Overdraft Lending: Very Large Financial Institutions” (Federal Register, vol. 89, p. 106,768 (Dec. 30, 2024). Pub. L. 119-10 (May 9, 2025).
10. Environmental Protection Agency, “National Emission Standards for Hazardous Pollutants: Rubber Tire Manufacturing” (Federal Register, vol. 89, p. 94,886 (Nov. 29, 2024). Pub. L. 119-14 (May 23, 2025).
11. Department of Interior, “Glen Canyon National Recreation Area: Motor Vehicles” (Federal Register, vol. 90, p. 2,621 (Nov. 29, 2024). Pub. L. 119-13 (May 23, 2025).
12. Environmental Protection Agency, “California State Motor Vehicle and Engine and Nonroad Engine Pollution Control Standards; The ‘Omnibus’ Low NOX Regulation; Waiver of Preemption; Notice of Decision’’ (Federal Register, vol. 90, p. 643 (Jan. 6, 2025). Pub. L. 119-17 (June 12, 2025).
13. Environmental Protection Agency, “California State Motor Vehicle and Engine Pollution Control Standards; Advanced Clean Cars II; Waiver of Preemption; Notice of Decision’’ (Federal Register, vol. 90, p. 642 (Jan. 6, 2025). Pub. L. 119-16 (June 12, 2025).
14. Environmental Protection Agency, ‘‘California State Motor Vehicle and Engine Pollution Control Standards; Heavy-Duty Vehicle and Engine Emission Warranty and Maintenance Provisions; Advanced Clean Trucks; Zero Emission Airport Shuttle; Zero-Emission Power Train Certification; Waiver of Preemption; Notice of Decision’’ (Federal Register, vol. 88, p. 20,688 (Apr. 6, 2023). Pub. L. 119-15 (June 12, 2025).
15. Environmental Protection Agency, “Review of Final Rule Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act’’ (Federal Register, vol. 89, p. 73,293 (Sept. 10, 2024). Pub. L. 119-20 (June 20, 2025).
16. Office of the Comptroller of the Currency of the Department of the Treasury, “Business Combinations Under the Bank Merger Act’’ (Federal Register, vol. 89, p. 78,207 (Sept. 25, 2024). Pub. L. 119-19 (June 20, 2025).