Project 2025’s plan for a potential second Trump administration outlines a clear strategy to drastically reduce immigration. One of its proposals directs the Department of Homeland Security to stop updating the list of countries eligible for H-2 visas. As a result, every visa petition would need to demonstrate that it serves U.S. interests in order to be approved. While this may seem like a simple, modest change, its implementation would intentionally disrupt two major seasonal guest worker programs, leading to severe labor shortages and widespread supply chain disruptions.
The H-2 visa program enables U.S. employers to hire foreign nationals for temporary work. Typically, applicants must be citizens of designated countries, which are chosen based on their strong compliance with the program’s rules. However, individuals from non-designated countries can still apply if the employer presents specific evidence. This includes demonstrating that no U.S. workers or eligible nationals from designated countries are available to fill the position, and that waiving the nationality requirement serves U.S. interests. If U.S. Citizenship and Immigration Services (USCIS) determines that the petition meets these criteria, it may grant a waiver, allowing the applicant to bypass the designated country requirement.
The H-2 eligible country list is a practical tool that enables the Department of Homeland Security to balance domestic labor needs with national security interests by assessing risk based on historical compliance data. Being on the list does not guarantee that citizens of those countries will automatically receive visas. Hiring companies are still evaluated by USCIS. Additionally, all workers –regardless of nationality–are subject to thorough screening by consular officers and border agents, who assess any potential risks related to their entry. Even after workers are admitted, the Department of Labor continues to oversee employer-side compliance on an ongoing basis.
H-2 visas are divided into two categories: the H-2A, which is used for agricultural workers and represents 70% of H-2 issuances, and the H-2B for non-agricultural workers represents the remaining 30%. The number of H-2 visas has been increasing significantly over the past ten years, tripling and growing approximately 15% annually on average. Issuances of H-2B visas have more than doubled over the past ten years, growing at nearly 10% per year on average. It is important to note that H-2B visas are subject to an annual cap of 66,000, although this limit can be increased at DHS’s discretion. In contrast, H-2A visas, which are for agricultural workers, are not subject to any numerical cap.
The designated country list, which identifies the countries whose nationals are eligible for H-2 visas, is updated annually as a part of a routine process within a much longer approval pipeline. However, the authors of Project 2025 have identified this list as a potential tool to undermine legal immigration. In fiscal year 2023, the U.S. The Department of State issued 310,676 H-2A and 131,704 H-2B visas, with only 176 of those going to nationals from non-designated countries–about 0.04% of the total. Project 2025 seeks to impose a much stricter approval threshold for each visa application. Given that the initiative proposes over 175 measures to restrict immigration, this approach appears to be a strategic attempt to cripple the H-2A and H-2B programs.
Waivers of the eligible-country list requirement are issued at USCIS’s discretion. Since there are no publicly available guidelines indicating which factors the agency considers when determining if a petition is in the U.S.’s interest, it is challenging to estimate how many visas would be issued if the country list were to be eliminated. While such a proposal could slow down processing times but still result in a similar number of visas being issued, it is more likely—especially considering other recommendations for USCIS recommendations in Project 2025—that this policy will be used to significantly reduce the number of H-2 visas issued. The stricter thresholds and added bureaucratic hurdles seem designed to dramatically decrease the overall issuance of these visas.
The impact of the proposal on the American economy would hinge on how many applications USCIS deems to be in the national interest. Petitions from individuals whose countries are not on the designated list would be assessed on a case-by-case basis, leaving approvals largely up to the discretion of the agency.
For example, if USCIS were to determine, based on the average visa growth rate from fiscal years 2014 to 2023, that only 10% of current H-2 visa applications met the “national interest” threshold, the U.S. economy would lose the opportunity to hire over 610,000 foreigners under the H-2 visa program in fiscal year 2026 alone. Over five years, this would result in the reduction of more than 4.1 million H-2 visas. Similarly, if USCIS determined that only 25% of current H-2 visas to be in the national interest, more than 510,000 workers would be excluded from the U.S. labor force in Fiscal Year 2026, leading to a five-year decrease of over 3.5 million visas. These reductions could severely impact industries that depend on seasonal and temporary foreign labor.
Reducing the number of H-2 visas could have a severe impact on the U.S. economy, particularly for the agricultural sector. The industry has been grappling with increasing labor shortages for years. In 2014, only 14% of farmers reported difficulties securing the labor they needed. By 2018, that number had risen to 41%, and it surged to a record high of 53% during the COVID-19 pandemic. Although the post-pandemic recovery has eased some pressure on the agricultural workforce, many farmers still face challenges in finding enough workers to sustain crop production. Restricting access to H-2A visas, which are essential for the agricultural labor force, would only worsen the already critical labor shortages farmers are experiencing, threatening crop yields and overall productivity in the sector.
Worsening labor shortages can also disrupt the agricultural supply chain, leading to a decline in the availability of farm products and driving up prices. To attract more workers, farmers may be compelled to raise wages, which would increase their operating costs. These higher labor expenses would likely be passed onto consumers, resulting in even higher grocery bills for Americans already grappling with inflation.
While the U.S. agriculture sector would be the most affected by eliminating the H-2 designated country list, this policy would also affect other industries that rely on the visa to fill labor shortages. H-2Bs are particularly popular in landscaping and groundskeeping sectors, accounting for 39% of approved H-2B labor certifications. The landscaping industry has suffered labor shortages for years, with 92% of employers experiencing at least some difficulty finding good employees. Reducing the availability of H-2B visas would likely exacerbate these shortages, not only in landscaping but also in other industries that rely heavily on non-U.S. citizens and are already facing hiring challenges. As with agricultural shortages, these workforce gaps could drive up operating costs, which would ultimately lead to higher consumer prices for services, placing additional financial pressure on businesses and households alike.
Project 2025’s proposal to eliminate the designated country list would not lead to added protection for American citizens, nor increased national security. Rather, it would increase the administrative burden on farm employers and USCIS, further exacerbate existing labor shortages, disrupt vital supply chains, and ultimately harm American consumers by driving up prices and limiting the availability of essential goods and services.