Trade Alert: 2025 Government Shutdown – What Importers Need to Know
As Congress approaches the September 30 deadline without a finalized budget or continuing resolution, importers should be aware of some possible disruptions across key federal agencies.
According to the Office of Management and Budget (OMB), agency contingency plans for a lapse in appropriations are hosted solely on each agency’s website.
The National Customs Broker and Forwarders Association of America (NCBFAA) held a webinar this morning with some insights.
U.S. Customs and Border Protection (CBP)
Essential operations will continue, including cargo inspections and port activities.
Expect delays in non-critical functions such as audits, ruling requests, and forced labor enforcement reviews.
Food and Drug Administration (FDA)
FDA will remain mostly operational, supported by user fee funding.
Entry reviews and exams will continue, especially for high-risk shipments.
Importers may face delays in clearance, particularly for perishables, due to staffing constraints and the new National Entry Review (NER) system.
https://www.hhs.gov/about/budget/fy-2026-fda-contingency-staffing-plan/index.html
U.S. Department of Agriculture (USDA)
Significant furloughs expected across USDA.
Import inspections will continue but may be delayed, especially for food safety and plant health programs. Issuance of electronic phytosanitary certificates will continue.
https://www.usda.gov/shutdownplans
U.S. Fish and Wildlife Service (FWS)
Expected to be operational during a shutdown since the agency is user-fee funded but may expect some delays in the event that the e-declaration portal is impacted.
Note: No updated information since the 2023 Contingency Plan: https://www.doi.gov/sites/default/files/doi-fws-contingency-plan-2023.pdf
Flegenheimer will continue to monitor and provide you with updates..
Thank you.
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