UPDATED: 10/1/2025—Key trade and tariff operations are moving forward largely unaffected by the recent government funding lapse.
- USTR is keeping all 237 employees on staff, emphasizing its role in advising the President on tariff negotiations.
- Commerce will continue most export control work, with the Bureau of Industry and Security retaining the majority of its staff. However, the International Trade Administration will scale back sharply, pausing much of its trade remedy administration.
- Homeland Security/CBP will maintain tariff collection without disruption, even as other parts of DHS see furloughs.
Overall, agencies have prioritized keeping trade enforcement and tariff-related functions running, minimizing impact to importers and exporters.
As October 1 approaches, there is growing concern that the federal government could shut down if Congress does not pass a continuing resolution by midnight on September 30. Such a lapse in funding would directly affect the processing of imports and exports at U.S. ports. While agencies including the Department of Commerce, Department of Homeland Security (DHS), Bureau of Industry and Security, and U.S. Customs and Border Protection (CBP) are preparing contingency plans, the full impact on trade remains uncertain.
DHS Procedures During a Funding Lapse
The DHS “Procedures Relating to a Lapse in Appropriations” provides guidance on managing operations during a funding lapse. It distinguishes between exempt functions, which can continue using non-annual or fee-funded resources, and excepted functions, which are essential for protecting life, property, or national security. Employees not performing these critical duties are furloughed, following clear procedures for notices, recalls, and documentation. DHS Components must execute an orderly shutdown of non-essential activities, maintain minimal staffing for essential operations, and coordinate closely with management and the Office of Personnel Management (OPM). In emergencies, employees may be recalled to handle incident-driven excepted functions, ensuring that critical operations continue despite the lapse.
Impact on Trade Operations
During a shutdown, essential personnel such as CBP officers and import specialists will continue working, though without pay. To keep the trade community informed, CBP plans to host a call on October 1 and provide daily updates. The National Customs Brokers & Forwarders Association of America (NCBFAA), in collaboration with trade representatives, has requested a “war room” with CBP and Partner Government Agencies to help coordinate and maintain the flow of goods. Mohawk Global is actively engaged in these efforts through its participation on NCBFAA’s Customs Committee and Federal Maritime Commission sub-committee, ensuring strong representation and open communication during this time.
Potential Disruptions
While we hope the impact will be minimal, clients should be aware that disruptions may occur, including delays in licensing, CBP rulings, export processing, agency communications, and help desk support. Absenteeism among essential personnel could also contribute to bottlenecks. The duration of any shutdown is difficult to predict, but current political divisions in Congress and the Administration’s unconventional approach may extend its length beyond recent years.
At Mohawk Global, we remain committed to keeping your shipments moving under these challenging circumstances. We will continue to monitor developments closely and share updates on any changes that could affect your business. For questions, please reach out to your Mohawk Global representative.