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Client Advisory: Potential U.S. Government Shutdown – Trade Impacts
Yesterday, President Donald Trump canceled a scheduled meeting with congressional Democrats aimed at averting a potential government shutdown. As of now, annual funding for the U.S. Federal Government is set to expire at midnight on September 30, 2025.
In the event of a shutdown, U.S. Customs and Border Protection (CBP) will continue to operate and facilitate the clearance of goods to maintain the flow of trade. However, Partner Government Agencies (PGAs)—including the Food and Drug Administration (FDA), Department of Agriculture (USDA), Environmental Protection Agency (EPA), among others—may experience reduced staffing levels. This could result in delays in processing import transactions and inspections.
We encourage clients to monitor PGA messaging closely.
Potential Impacts by Agency
– CBP (Customs and Border Protection): As a law enforcement entity we anticipate that CBP will remain operational. Ports will stay open, and cargo clearance, security, and revenue collection will continue. However, administrative and support functions—such as refunds, ruling requests, audits, and document responses—may be delayed due to furloughs.
– CBP Deadlines: Enforcement of importer deadlines (e.g., Protests, Drawback Claims, CF 28/29 responses) will continue. Importers must adhere to these timelines, even if CBP is unable to meet its own.
– FDA (Food and Drug Administration): Critical functions such as entry reviews, exams, high-risk investigations, and recalls will continue. However, reduced staffing may lead to slower processing times.
– USDA (Department of Agriculture): Delays are expected due to limited staffing. Please note some agricultural functions are fee funded which may lesson impact in certain areas.
– EPA (Environmental Protection Agency): Processing delays are anticipated due to reduced operational capacity.
– Other PGAs: Impacts will vary by agency. Clients should expect delays and monitor communications closely.
– International Trade Commission (ITC): Expected to be furloughed. Updates to the Harmonized Tariff Schedule may be delayed.
– CTPAT: No impact anticipated.
– Bureau of Industry & Security (BIS): Export controls enforcement will continue. Licensing and advisory services may be suspended.
– Transportation Security Administration (TSA): TSA personnel are required to work during a shutdown, though staffing challenges may lead to delays in air cargo processing and airport operations.
– Air Traffic Controllers: Will remain on duty, but absenteeism could disrupt airport operations, as seen in previous shutdowns.
We are actively monitoring the situation and will provide timely updates as developments occur. If you have any questions or concerns, please contact us at transitionteamus@willsonintl.com .
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