U.S. Trade-Related Agencies’ Shutdown Plans Amid Funding Lapse

Trade Update • Oct. 3, 2025

Key Points

• Essential trade-related functions linked to national security and presidential duties will continue with limited staffing.
• Trade enforcement, tariff administration, border inspections, and trade negotiations remain operational.
• Routine administrative, regulatory, and support activities are paused until funding is restored.
• USTR will prioritize international trade negotiations and tariff enforcement using no-year funds.
• DHS and CBP will maintain core border security, cargo inspections, and tariff collections without disruption.
• DOC, FDA, TTB, and USITC will focus on critical national security and enforcement roles, suspending non-essential tasks.

On October 1, 2025, the U.S. government shut down after Congress failed to pass a funding bill. Trade-related functions deemed essential to national security and the President’s constitutional duties will continue with limited staffing and resources. Key trade enforcement, tariff administration, border inspections, and trade negotiations will proceed, while many routine regulatory, administrative, and support activities are paused.

Here are some of the key trade agencies affected and their shutdown plans:

United States Trade Representative (USTR)

USTR’s shutdown plan confirms that the agency will continue essential functions tied to the President’s constitutional duties, particularly foreign relations and international trade negotiations. USTR will use no-year funds to maintain operations as long as possible, focusing on high-priority activities like advising the President on tariffs under the International Emergency Economic Powers Act (IEEPA) and enforcing trade agreements.

Routine administrative functions and non-essential engagements with trading partners will be paused. USTR will follow orderly shutdown procedures, including furlough notices.

Department of Homeland Security (DHS)

DHS’s shutdown plan states the agency will maintain essential functions during the shutdown, including Customs and Border Protection (CBP) operations such as cargo inspections, tariff collection, and border security enforcement. Ports of entry remain open and fully staffed.

Non-essential functions like training, audits, and certain investigations (including forced labor cases) may be delayed or paused.

Customs and Border Protection (CBP)

The DHS’s shutdown plan also confirms that CBP will remain fully operational, with ports of entry staffed to process cargo and travelers, continue tariff collections, and maintain trade enforcement. Third-party trade advisory services and news sources have independently confirmed CBP’s commitment to uninterrupted core functions such as inspections, permit processing, and trade communications during the shutdown.

Some non-essential activities like audits, training, and certain investigations may be delayed, but no overall disruption to CBP’s primary trade role is expected.

Alcohol and Tobacco Tax and Trade Bureau (TTB)

TTB shutdown plan confirms that during a government shutdown, the bureau will furlough 398 of its 459 employees. Only 61 staff will continue essential functions such as processing tax returns with payments, maintaining computer operations to avoid data loss, protecting bankruptcy and lien cases, securing federal property, and conducting criminal enforcement.

Most administrative functions, including permit processing, certifications, formulas, drawback claims, audits, and laboratory services, will be suspended.

Department of Commerce (DOC)

The DOC shutdown plan states that most services and activities of its operating units, including the International Trade Administration (ITA), Census Bureau, Bureau of Economic Analysis, and Economic Development Administration, will cease during a funding lapse.

However, DOC will continue export enforcement, criminal investigations, and ongoing Section 232 national security work. Essential functions such as weather forecasting, fisheries management, and critical infrastructure monitoring will operate if funded by non-annual resources.

Food and Drug Administration (FDA)

The FDA will continue essential public health activities during the shutdown, including monitoring and responding to outbreaks, overseeing food and medical product recalls, pursuing investigations where imminent risk to health exists, and screening imports to protect consumers. Critical surveillance for medical device safety will also continue.

However, the FDA will not process new drug or device applications requiring fees nor accept fee payments until appropriations are restored. Routine inspections, new submissions, and safety initiatives unrelated to imminent threats will be paused during the funding lapse, according to its shutdown plan.

U.S. International Trade Commission (USITC)

The USITC shutdown plan states that during a funding lapse, the USITC will cease all activities except those required for protection of life or federal property, maintenance of network and physical security, and ongoing litigation with no granted time extensions.

It will maintain the Harmonized Tariff Schedule of the United States to ensure consistent tariff application. Investigative activities, technical assistance to the U.S. Trade Representative and Congress, and processing of Freedom of Information Act requests will be suspended until funding resumes.

How GHY Can Help?

GHY specializes in helping businesses navigate and reduce the impacts of tariffs through strategic solutions tailored to their needs. Our experts can audit your supply chain to identify inefficiencies, uncover cost-saving opportunities, and ensure compliance with evolving trade regulations. We also employ tariff engineering techniques to optimize product classification and sourcing strategies, minimizing duty exposure and maximizing profitability.

By partnering with GHY, your business gains access to the tools and expertise needed to streamline operations and stay competitive in a challenging trade environment.

Contact Us Today! Booking a Meeting, email consult@ghy.com, or call +1 (800) 667-0771.