Operational Impact

U.S. Government Shutdown: Key Updates and Trade Implications - October 7, 2025

Written by Expeditors | Oct 7, 2025 11:23:14 PM

This update serves as a follow-up to our initial operational impact communication issued on October 1, 2025, regarding the U.S. government shutdown. As of October 7, several government agencies have released additional guidance and updates in response to the ongoing shutdown. The information below summarizes the latest changes affecting federal operations, licensing, and trade activities. 

We are closely monitoring the situation to ensure minimal disruption to your operations and to provide timely updates as the situation evolves.

 
Agency Update Source
Commerce Department
(DOC)

ACCESS system updates are paused; most export license applications are suspended, except for emergencies; some trade and import licensing functions continue for national security purposes. DOC Contingency Plan
Bureau of Industry and Security (BIS) Continues to review and process emergency export license applications and draft regulations related to U.S. and allied military activities, as well as the protection of U.S. property and human life; most other export license processing is suspended. Homepage | Bureau of Industry and Security
U.S. Trade Representative (USTR) USTR remains fully operational due to supplemental appropriations; no staff furloughs; USMCA enforcement continues. Greer: USTR will be firing ‘on all pistons’ if government shuts down | InsideTrade.com
U.S. International Trade Commission (USITC) Most trade remedy investigations and technical assistance have been suspended; only essential litigation and tariff schedule maintenance continue. usitc_fy_2026_lapse_plan.pdf
Court of International Trade Remains open and fully operational; electronic filing and deadlines unchanged unless ordered otherwise. NOTICE REGARDING COURT OPERATIONS: | Court of International Trade | United States
State Department (DDTC)

Export licenses and related services halted; ongoing requests remain pending until funding resumes.

Home - DDTC Public Portal - DDTC Public Portal
Treasury (OFAC) Sanctions licensing activities have ceased during the shutdown. Lapse in Appropriations Contingency Plan | U.S. Department of the Treasury
Customs and Border Protection 
(CBP)

During an Oct. 6 trade outreach call, CBP confirmed that refunds, including drawback and ACH, are not allowed during the shutdown due to funding restrictions. The agency is reviewing this guidance and will resume processing if new instructions are received.  

What You Can Do

  • Plan Ahead: If your shipments require clearance from agencies beyond CBP, anticipate possible delays and adjust timelines accordingly.
  • Stay Up to Date: We will continue to monitor agency-specific developments and share relevant updates as they become available.
  • Reach Out: If you have questions about how this may affect your shipments, don't hesitate to get in touch with your Expeditors’ representative.

As the shutdown continues, additional impacts may emerge across regulatory and operational domains. Updates will be communicated as warranted to help you stay informed and prepared. 

Contact your local Expeditors representative to find out how this could affect your cargo.