Government Shutdown Update – Impact on Trade Operations
- October 1, 2025
As you may be aware, the U.S. government has entered a shutdown. We want to provide you with the most up-to-date information on how this may affect trade operations and related agencies:
Customs and Border Protection (CBP)
- All CBP staff are considered “excepted employees” and remain at work. Ports of entry are open, and there is currently no impact on cargo clearance, liquidation, or related processes.
- Executive Orders will continue to be processed.
- In past shutdowns, the U.S. International Trade Commission (ITC) was furloughed, preventing HTS updates in the system. It is not yet clear if that will occur again — a potential concern given recent Executive Order activity.
- CBP has not yet determined whether the Customs Broker License Exam will be postponed.
- Greater scrutiny on CBP travel may occur.
- The finance/revenue division’s ability to process refunds is uncertain and may depend on available government funding.
- Rulings, Fines, Penalties, and Forfeitures will remain open.
- ABI representatives will remain available.
- The African Growth and Opportunity Act (AGOA) expired yesterday; reinstatement will require congressional action.
Partner Government Agencies (PGAs)
- EPA: The shutdown poses serious challenges, with potential disruptions to operations and workforce. The agency’s ability to maintain essential services during the funding lapse is uncertain, and the situation remains fluid.
- FDA: Operations continue as permitted by law, including activities addressing imminent threats to human life and those funded by carryover user fee funds.
- CPSC: Will continue critical work to protect against imminent threats to life and property, including port screenings for hazardous products, injury monitoring, and urgent enforcement actions such as recalls.
- APHIS/USDA: Mission-critical functions will continue, and the agency’s website will be updated periodically during the funding lapse.
- FWS: Due to the shutdown, fws.gov is not being updated, and the agency cannot respond to inquiries until appropriations are enacted.
Here are the links to websites, for your reference:
Bureau/Office Contingency Plans
- Assistant Secretary for Indian Affairs (ASIA)
- Assistant Secretary for Insular and International Affairs (ASIIA)
- Bureau of Indian Affairs (BIA)
- Bureau of Indian Education (BIE)
- Bureau of Land Management (BLM)
- Bureau of Ocean Energy Management (BOEM)
- Bureau of Reclamation (BOR)
- Bureau of Safety and Environmental Enforcement (BSEE)
- Bureau of Trust Funds Administration (BTFA)
- U.S. Fish and Wildlife Service (FWS)
- National Park Service (NPS)
- Office of the Inspector General (OIG)
- Office of the Secretary (OS)
- Office of Surface Mining Reclamation and Enforcement (OSMRE)
- Solicitor’s Office (SOL)
- U.S. Geological Survey (USGS)
What This Means for You
As it stands today, CBP remains “open for business” and ports are operating normally. However, as the situation develops, certain agencies may experience disruptions, delays, or reduced capacity.
Shapiro will continue to monitor developments closely and provide updates as new information becomes available.