All signs at this juncture indicate there will be a federal government shutdown beginning midnight Saturday, September 30, 2023. The length of the shutdown is unknown, but there is speculation it could last weeks. Here is a summary of what is known to date.

• Please see our “What’s New” client briefings from September 27.
• CBP: CBP field trade processing (Centers for Excellence & Expertise (CEE) Import Specialist, Entry Specialist, FP&F, etc.) personnel numbers should be largely unimpacted. There will be a skeleton staff at CBP Headquarters Office of Trade. CBP ABI client reps will be furloughed, but CBP HQ Office of Information and Technology will be staffed. ABI questions may be directed to [email protected]. Expect delays for review of UFLPA detention documentation at CBP HQ.
• EPA: EPA Regional staff will largely be furloughed. EPA just posted a Contingency Plan for Shutdown. Automated EPA “May Proceeds” should continue, but no or limited EPA staff will be available to review manual Notices of Arrival. Despite the issuance of “May Proceeds,” EPA reserves the right to request inspections for 30 days. Do not expect responses to calls or emails.
• FDA. About 80% of FDA staff will not be furloughed, partly due to carryover funding from user fees disconnected from appropriations. There could be furloughs at ports and delays, so consider closely monitoring FDA entries in ITACS.
• CPSC: Most CSPC staff will be furloughed.
• Census: Census staff furloughed, but call center will be available to receive messages.
• Commerce: Commerce has published an updated Plan for Orderly Shutdown Due to Lapse of Congressional Appropriations indicating, in part, that steel and aluminum import licensing system will be shut down, and it may require up to two days to advise stakeholders on shutdown and procedures. Importers should review CBP CSMS messages for updates.
• USITC: HTS website may not be updated. Consider downloading HTS for reference purposes: https://hts.usitc.gov/.
• OFAC: OFAC will be staffed, but expect delays in responses.
• BIS: Expect delays with SNAP-R processing.

For assistance during the federal government shutdown, please contact Marshall Miller, Sean Murray, Brian Murphy, Bryan Brown, or Linda King.