Updated October 13, 2025:

The government shutdown is entering its third week. Here’s the latest on CBP and select Partner Government Agencies (PGAs):

• U.S. Customs and Border Protection (CBP): CBP has stated repeatedly on trade calls that the flow of cargo and passengers would continue as normal, as CBP’s budget is unaffected by the shutdown and the agency remains at full staff. CBP’s agriculture specialists are still at the borders and conducting inspections as normal. That said, CBP did confirm that it would not issue any refunds, meaning importers of record (IORs) won’t receive refunds.
• Environmental Protection Agency (EPA): For the most part, we are seeing normal operations. EPA’s enforcement (in combination with CBP) for certain compliance functions remains unaffected, though large numbers of other personnel have been furloughed. Overtime, inspections, and manual Notice of Arrival of Pesticides and Devices (NOA) approvals will take longer as frontline operators are tasked with more administrative functions.
• U.S. Department of Agriculture (USDA): While CBP’s agriculture specialists are unaffected, USDA’s Animal and Plant Health Inspection Service (APHIS) has furloughed about 10% of its workforce, mostly focused on non-critical functions like IT and HR. While these furloughs have not directly affected operations yet, a potential extended shutdown would require frontline staff to take on more administrative and support functions. This would take time away from import inspections.
• Food and Drug Administration (FDA): We are starting to see more FDA holds and exams pile up. We heard previously that ~20% of staff would be furloughed, but it seems these are taking longer to resolve and the FDA is not replying in a timely manner. FDA’s public guidance suggests a pause in device and drug registration processing to focus on enforcement, but anecdotally, hold resolution times are increasing.
• U.S. Fish and Wildlife Service (FWS): The agency has seen minimal impact, as it is almost entirely funded by user fees. However, there will be reduced administrative functions within license processing and other areas.
• Consumer Product Safety Commission (CPSC): This is the first shutdown since CPSC expanded their ACE functionality. Previously, CBP would automatically remove CPSC holds during shutdowns, except in cases where PGA had requested a review. At this time, we are seeing fewer CPSC holds and quick resolution.

Updated October 7, 2025:

Yesterday (October 6), CBP confirmed on a trade outreach call that it will not issue any refunds during the government shutdown. That applies to both ACH and check refunds, along with drawback claim payments, protests, post-summary corrections, and any other payment involving a check from the Treasury Department.

CBP did not issue any refunds scheduled for last Tuesday. Additionally, for protests that have already been approved, importers do not need to take any further action during the shutdown.

Originally Published October 1, 2025:

At midnight today, October 1, the U.S. government entered an official shutdown after Congress failed to pass a short-term government funding bill. Mass furloughs are expected to impact hundreds of thousands of employees, disrupting operations across a wide range of federal agencies.

However, most customs and entry functions remain unaffected. The Department of Homeland Security has declared security and revenue collection an “essential” operation, meaning U.S. Customs and Border Protection (CBP) will continue to collect tariff revenue and businesses will remain subject to all existing and upcoming duties throughout the shutdown.

Specific Impacts on Federal Agencies Related to Trade

• Customs and Border Protection (CBP), the primary federal agency tasked with handling imports and collecting tariff revenue, is entirely exempt from furloughs. The agency does not expect any reductions in capabilities.
  • Operations will continue as normal across all CBP divisions, including Fines, Penalties, and Forfeitures (FPF); agriculture specialist teams; and all “back-end” functions, including support for the Automated Commercial Environment (ACE) and the Automated Broker Interface (ABI).
  • CBP intends to implement all upcoming tariffs as planned, including those set to take effect on October 14. Even if the International Trade Commission (ITC) delays publishing the updated version of the Harmonized Tariff Schedule (HTS), importers should expect new duties to take effect as scheduled.
  • Duty refunds will continue to be processed throughout the shutdown. For importers who have yet to receive a check or ACH payment for a processed refund, note that the U.S. Treasury may currently lack the funds to issue refunds in a timely manner.
  • CBP will continue to send out messages via its Cargo Systems Messaging Service (CSMS).
  • CBP’s Centers of Excellence and Expertise (CEEs), which process entry summaries, protests, liquidations, and other post-release trade activities, will remain open. The shutdown will not impact any liquidation dates.
  • Coordination with Partner Government Agencies (PGAs): Should issues arise, CBP has indicated that it has tools in place to carry out collaborative functions involving PGAs.
• Partner Government Agencies (PGAs), which work closely with CBP to regulate imported goods, will see a number of furloughs and delays.
  • U.S. Fish and Wildlife (FWS) will experience delays in permit processing and exams.
  • The Federal Drug Administration (FDA) will reduce staffing for enforcement, and will see exam delays.
  • The Environmental Protection Agency (EPA) will experience delays in processing Notices of Arrival of Pesticides and Devices (NOAs). Exams will also be delayed.
  • The U.S. Department of Agriculture (USDA) may see delays, but should be fully funded in the short term.
  • The National Oceanic and Atmospheric Administration (NOAA)’s Seafood Import Monitoring Program (SIMP) is expecting a full furlough, with limited import reviews.
  • The Consumer Product Safety Commission (CPSC) is expecting a full furlough, with limited import reviews.
• The U.S. Trade Representative (USTR), which guides CBP on Section 232 duty enforcement and collection, conducts national security investigations, and helps drive trade agreement negotiations, does not intend to furlough any of its employees.
  • The USTR previously indicated that it would furlough 94 of its employees, but the agency walked back those plans yesterday. To continue operations, the USTR intends to leverage funds outside of the annual appropriations process.
  • Active Section 232 investigations will continue during the shutdown.
• The International Trade Administration, which reviews cases related to antidumping and countervailing duties (ADCVD), intends to furlough 1,230 of its 1,300 employees.
  • Given these furloughs, ADCVD investigations will slow considerably.

What Happens Next?

As the shutdown continues, all tariffs will be collected and implemented as usual. Should specific agency circumstances change, we will notify customers accordingly and provide guidance on any next steps.

Reach out to your Flexport account manager with any questions, or contact our customs and trade advisory experts at advisory@flexport.com.