Regulatory Crackdown on CDLs and Declining Imports Threaten US Supply Chain Stability
New FMCSA regulations targeting non-domiciled commercial driver's licenses combined with declining import volumes are creating significant capacity constraints and financial pressures across the US logistics industry.
The US supply chain faces mounting pressure from regulatory changes and declining import volumes, according to the latest ITS Logistics US Port/Rail Ramp Freight Index. While port and rail ramp operations currently run smoothly, the combination of new commercial driver's license enforcement and reduced container volumes threatens to disrupt market stability during what should be peak shipping season.
Import volumes continue their downward trajectory, with September projections at 2.12 million TEUs representing a 6.8% year-over-year decrease from August's 2.28 million TEUs. The National Retail Federation anticipates further declines through year-end, attributing the trend to tariffs and frontloading activity earlier in 2025. This sustained reduction in container demand has prompted ocean carriers to strictly enforce accessorial fee schedules to maintain profitability, placing additional financial strain on shippers.
More significantly, regulatory changes are creating what Paul Brashier, Vice President of Global Supply Chain for ITS Logistics, describes as "storm clouds on the horizon." Following a nationwide audit of CDL licenses, the Federal Motor Carrier Safety Administration issued an emergency interim ruling on September 26 restricting eligibility for non-domiciled CDLs. Several states have since implemented enforcement efforts to verify CDL compliance and English language proficiency at weigh stations, ports of entry, and major transportation routes.
Industry experts warn that non-domiciled CDL holders account for a substantial portion of lower-cost capacity, and the regulatory crackdown will likely trigger a surge in bankruptcies among small and mid-size carriers. The drayage market has already seen multiple major providers close their doors throughout 2025, and stricter enforcement is expected to exacerbate financial challenges while pushing additional capacity out of the market.
"In the near term, these new regulations will remove capacity from the ecosystem and cause market disruption," Brashier explained. "In the long term, it could drive many carriers out of business as they struggle to withstand both evolving regulatory pressures and the ongoing freight recession that has pushed rates down to or below operating levels."
The compounding factors of regulatory pressure and declining volumes are placing downward pressure on an already soft drayage market, creating potential problems for shippers in both immediate and future planning. Brashier emphasized that vetting service provider health will become increasingly important as shippers begin late 2025 and early 2026 RFP activity.
Shippers are advised to review their supply chains for inefficiencies that could be penalized under the renewed focus on accessorial fees. Brashier recommended confirming that accessorial dispute processes and documentation requirements are clearly defined in standard operating procedures. For supply chains utilizing rail for ocean container movement, understanding chassis pool flip policies and resolution procedures within free time becomes critical.
The ITS Logistics US Port/Rail Ramp Freight Index provides comprehensive forecasting for port container and dray operations across Pacific, Atlantic, and Gulf regions, along with ocean and domestic container rail ramp operations for both West Inland and East Inland regions. A full copy of the index with detailed forecasts is available at https://www.its4logistics.com.