As Congress’ funding deadline has passed, the federal government has entered a shutdown. While CBP has confirmed that they are fully operational and essential tasks such as cargo screening, inspections and enforcement will continue, other federal agencies that support trade may experience cutbacks or furloughs. Although ports will remain open and cargo will continue to move, clients should anticipate possible delays in shipments requiring multi-agency coordination. CBP has confirmed that tariff collections will proceed without interruption.
Partner Government Agencies (PGAs)
- Food and Drug Administration (FDA): Potential delays in food, drug and medical device approvals.
- U.S. Department of Agriculture (USDA) and Fish and Wildlife Service (USFWS): Possible slowdown in inspections and certifications, but they should continue to be processed.
- Other PGAs, such as Environmental Protection Agency (EPA) and Consumer Product Safety Commission (CPSC): Reduced staffing may increase clearance times for regulated goods.
We recommend closely monitoring cargo status and building in additional lead time for products requiring FDA, USDA, EPA, CPSC, or other PGA review. While CBP will remain operational, we anticipate delays due to reduced staffing among the PGAs.
Section 232 Investigations
The Trump administration plans to continue tariff-related investigations despite the federal government shutdown. The Commerce Department intends to move forward with work related to assessing the impact of imports on national security, marking a shift from earlier guidance that would have limited investigations once funding lapsed. This reflects a broader strategy to prioritize trade cases tied to national security despite budgetary gaps.
