Procurement Risk Briefing

Panama Canal restored capacity but warns on 2027 dry-season water; slot competitions November 17 and 24 · C.H. Robinson to buy RXO, close expected first half of 2027 — assignment, continuity and a third bidder before then · FMCSA proposal: English-proficiency out-of-service past the U.S.-Mexico border zones · Flexport lets AI agents create bookings — who approved that spend · Taylor Farms suspends central-Mexico iceberg lettuce May–August, indefinitely · 10-min read

About $126 billion in IEEPA tariff refunds has been paid to importers of record with interest (CBP, October 6) — four questions to ask each importing supplier that surcharged you in 2025, and why to settle pass-back before the court rules on the Section 301 forced-labor tariffs · Since September 18, CBP voids importer of record numbers over inaccurate Form 5106 data, and a voided number cannot enter goods · On September 29 a list of Canadian goods moved from a 50% duty to an import ban; check the current annexes by HTS code · 10-min read

FMCSA's revoked-ELD list holds 387 device registrations, 102 dated 2026 — and for five devices removed on August 6, drivers still using them are placed out of service from October 6; ask your core carriers which ELD they run and check it against the list · FMCSA has suspended biennial-update enforcement and USDOT inactivation for updates due on or after June 1, with no end date posted, so an active USDOT number is weaker evidence that a carrier's record is current · DOE weekly diesel set a record three weeks running, reaching $6.529 for the week of September 21, 71.9 cents over the 2022 peak — check what your surcharge table says above its top row · 8-min read

Cargo theft via trusted-account takeover walks straight through carrier qualification: CargoNet tracked 273 incidents worth $31.8 million across the Labor Day periods of 2021-2025, entering through compromised carrier accounts, email, phones or compliance platforms and changing delivery instructions after a legitimate carrier takes possession — the countermeasure is a change-authentication clause in your transportation agreements, not another screening tool · CBP's September 2 advance notice (docket USCBP-2026-1058) asks 64 questions about whether importers must produce their foreign suppliers' export declarations, names D-U-N-S, GLN, LEI and Altana ID as candidate replacements for the MID, and takes comments until December 1, 2026 — before any regulatory text exists · FMCSA is warning that lookalike sites are impersonating Motus, the registration portal carriers log into — the verify step your team runs on a flagged carrier is the step a phishing link hijacks · 8-min read

Broker liability verdicts have repriced freight broker insurance — excess/surplus coverage up 50% to triple digits, small brokers going from roughly $10K to $30-40K annually, two underwriters moving paper to the London market — turning your 3PL's insurance adequacy into a service-continuity question · The STB's $85B Union Pacific–Norfolk Southern review is live, with shipper comments, protests, and requests for conditions due November 18, 2026 · Three federal moves (broker transparency at OIRA, the 2027 split-duty pilot monitoring shipper detention, and the August 31 emergency removal of 110-plus driver-training providers) are shifting carrier proof burdens onto buyers — and the removed-provider list is public, so 'we check CDLs' stops being an acceptable answer · 8-min read

FMCSA finalized deregulatory rules effective July 22 (no printed ELD manual, no CDL violation self-reporting) that cut carrier paperwork and cost — a rate-negotiation lever for shippers while parcel demand stays soft · The tariff-optimization rush is creating hidden export-control exposure: reclassifying a product for a lower HTS rate can move its ECCN into a controlled category, and BIS's Affiliates Rule auto-reinstates Nov 10, 2026, making fast supplier switches a dormant licensing liability · 5-min read

The U.S. declined to extend USMCA for another 16 years — a $1.58T agreement is now on an annual review clock (next deadline July 1, 2027; it stays in force until at least 2036), repricing cross-border sourcing assumptions yearly · 'Ghost carriers' buy dormant motor-carrier numbers for a few thousand dollars and pass every standard broker check — 45% of cargo theft now involves fraud, one incident cost $3.5M in hours · 5-min read

CBP's CAPE portal is refunding the IEEPA tariffs the Supreme Court struck down — ~$28.7B in phase one, $11.4B more in late July, but eligibility runs on an 80-day liquidation clock · A decertification suit against NY + CA CDL programs, 13,000 cancelled non-domiciled licenses, and a proposed 'high-risk carrier' list are pulling capacity out of the market — lock freight rates before it tightens · 5-min read

Reefer diesel is taxed but never touches the highway — the 24.3¢/gal federal excise is refundable via IRS Form 4136 (Prime is suing the IRS for $11M over it; small carriers can claim it too) · California's HVIP + CCFR stack cuts up to 90% off a zero-emission Class 8 truck, but day-cab-only and first-come funding hide inside the $50k headline · 4-min read

SCOTUS kills broker preemption shield (Montgomery v. Caribe) · White House EO adds criminal enforcement across the chain · FMCSA thins carrier data as audits spike and 90% of carriers go unrated · 4-min read

US customs-rule overhaul: re-audit importer-of-record · EU-US tariff deal re-prices transatlantic lanes · tariff + transfer pricing as one number · 4-min read

USDOT visibility mandate: map vs decision · FMCSA carrier-safety signal degrading · tariff & air-freight cost shock · 4-min read

NPM worms as vendor risk · FMCSA MOTUS meltdown · FedEx LTL spin-off resets benchmarks · 4-min read

FMCSA high-risk carrier list · post-Montgomery liability · tariff refund eligibility · 4-min read