USDA is currently open and fully operational. If you are searching whether the USDA is shut down right now, the short answer is no. The FY2026 government shutdown ended on November 12, 2025 — 43 days after it began on October 1, 2025 — when Congress passed and President Trump signed appropriations legislation providing full funding for USDA through September 30, 2026. The USDA government shutdown that ran from October 1 to November 12, 2025 is now a matter of historical record — and a directly instructive one for any food manufacturer, agricultural business, or regulated entity that needs to understand what a funding lapse actually means for operations.
That record now includes new variables. USDA has undergone significant workforce reductions and structural reorganization in 2025–2026. The agency that would manage a potential October 1, 2026 funding lapse — when FY2027 appropriations must be in place — may operate differently from the agency that managed the October 2025 shutdown. This guide covers what happened during that 43-day closure, how each major USDA sub-agency operates when funding lapses, what reported workforce and structural changes mean for future shutdowns, and what your business should do before the next potential lapse date.
Current USDA Operating Status (March 2026)
The October 2025 USDA government shutdown is over. Here is the agency status as of March 2026:
- Overall USDA status: Fully funded and operational through September 30, 2026
- FSIS inspections: Operating at full capacity
- FSA county offices: Open and processing loan applications
- National Organic Program: Active; backlog from the 43-day shutdown largely cleared
- APHIS services: Fully operational; emergency disease response programs active
- AMS programs: Packers and Stockyards enforcement, Country of Origin Labeling compliance, and Bioengineered Food Disclosure enforcement all restored
- Next funding risk: October 1, 2026 (FY2027 appropriations deadline)
The shutdown that closed large portions of USDA from October 1 to November 12, 2025 established new records for its duration and created significant operational backlogs across USDA programs. Understanding what actually happened — and what a repeat would look like under a restructured agency — is practical information for any business operating in regulated food, agriculture, or export markets.
What Happened During the October 2025 USDA Shutdown
The FY2026 government shutdown began at 12:01 a.m. on October 1, 2025, when Congress failed to pass appropriations legislation or a continuing resolution before the fiscal year deadline. According to USDA's FY 2026 Lapse of Funding Plan, approximately 42,256 of the agency's 96,931 employees — representing 49% of the workforce — were furloughed at the start of the shutdown.
The shutdown lasted 43 days, surpassing the 2018–2019 closure at 35 days to become the longest government shutdown in U.S. history. It ended November 12, 2025, when Congress passed and the President signed appropriations legislation that fully funded USDA programs through September 30, 2026.
Key Timeline Events
For food manufacturers and importers, the 43-day duration created meaningful operational friction. Label approvals that would normally take weeks stretched into months. NOP compliance timelines shifted. FSA-dependent agricultural operations faced acute cash flow pressure during the county office closure period. The practical lesson from October 2025 is that shutdown planning cannot be based on contingency plan projections alone — it requires understanding what actually happens at each duration milestone.
USDA Agency Operations During Government Shutdowns
This detailed breakdown shows how each major USDA agency operates during government shutdowns, including staff retention rates from the October 2025 shutdown and impacts on regulated businesses. According to the U.S. Department of Agriculture's contingency planning documents, retention rates vary significantly based on funding sources and statutory requirements.
| Agency | Staff Retained | Key Functions Continuing | Key Functions Suspended | Impact on Regulated Industry |
|---|---|---|---|---|
| FSIS — Food Safety and Inspection Service | 89% (7,690 of 8,688) |
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| Minimal Impact — Processing plants operated normally with continuous inspection coverage. Label approval backlogs accumulated throughout the 43-day period. |
| APHIS — Animal and Plant Health Inspection Service | 54% (4,662 of 8,611) |
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| Moderate Impact — Export certificate processing delays grew throughout the shutdown; emergency disease response including active HPAI programs continued without interruption. |
| AMS — Agricultural Marketing Service | 85% (3,803 of 4,478) |
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| Significant Impact — Organic certification oversight suspended for the full 43-day period. Voluntary fee-funded grading continued without interruption. |
| FSA — Farm Service Agency | 24% (2,577 of 10,898) |
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| Severe Impact — Agricultural lending and disaster payments halted October 1–23. Full restoration only upon the November 12 shutdown resolution. |
Source: USDA Contingency Plan Summary; USDA FY 2026 Lapse of Funding Plan operational data
FSIS Operations: Meat and Poultry Inspection During Shutdown
The Food Safety and Inspection Service maintains its mission-essential functions throughout government shutdowns because meat and poultry inspection directly protects public health. According to the FSIS Contingency Plan, the agency operates under statutory inspection requirements that classify its core work as essential to preventing immediate threats to human life.
Activities That Continue
During government shutdowns, FSIS retains approximately 89% of its workforce — more than 7,690 employees — to perform mandatory inspections. These operations continued without interruption throughout the October 2025 shutdown:
- Statutory inspection of meat, poultry, and egg products at processing facilities under the Federal Meat Inspection Act, Poultry Products Inspection Act, and Egg Products Inspection Act
- Investigation and response to foodborne illness outbreaks, including coordination with the USDA product recall process when contamination issues arise
- Recall coordination and management of product safety actions
- Essential laboratory testing and pathogen analysis
- Enforcement actions addressing imminent health hazards
This operational continuity means food manufacturers can maintain production schedules without interruption to inspection services during most shutdown scenarios. Processing facilities should still plan for delays in administrative matters, policy guidance, and label reviews during extended closures. Reviewing your facility's USDA inspection readiness is particularly important before any potential shutdown window, so open compliance questions can be resolved while the agency is fully staffed.
Services That Cease
Non-essential FSIS functions halt during funding lapses. The agency suspends most training programs, administrative support functions, and policy development initiatives. The FSIS Contingency Plan specifically addresses cooperative state inspection program funding, noting that State-run Meat and Poultry Inspection programs operating in cooperating states may face funding shortages if shutdowns extend beyond initial contingency reserves — a particular concern for the 27 states that operate their own programs under cooperative agreements.
These suspended activities create longer-term compliance challenges as regulatory guidance stalls and policy questions remain unresolved. The 43-day October 2025 shutdown generated a label approval backlog that processing facilities were still working through weeks after the November 12 resolution. For a broader view of your USDA and FSIS compliance obligations and how shutdown-era administrative gaps affect your compliance timeline, contact our regulatory team.
FSIS Capacity and the DOGE Workforce Changes
A development affecting FSIS's shutdown capacity going forward: publicly available reporting and USDA workforce disclosures indicate the agency has experienced staffing reductions as part of broader DOGE-related reorganization across the department. While OFW attorneys are monitoring the full picture as information becomes available, the relevant planning consideration is this: the 89% retention rate that FSIS maintained during October 2025 would apply to a smaller total workforce baseline if further reductions occur before any subsequent funding lapse. For food manufacturers dependent on continuous FSIS inspection coverage, tracking agency staffing levels through USDA official channels and Congressional oversight reporting is advisable as part of shutdown contingency planning.
How USDA Reorganization Efforts May Affect Future Shutdowns
The most significant development since the October 2025 shutdown is not the shutdown itself — it is the structural and workforce changes underway at USDA that may reshape how the agency handles any subsequent funding lapse. Food manufacturers, importers, and agricultural businesses that use prior shutdown experience as a planning baseline should account for a department that is actively reorganizing.
The Announced USDA Reorganization Plan
USDA Secretary Brooke L. Rollins announced a major organizational restructuring of the department, which USDA has publicly described as involving the relocation of personnel from Washington, D.C. headquarters to regional offices across the country. USDA has announced the disposal of its South Building and relocation of FNS, while the full scope of broader reorganization plans has not yet been publicly detailed. Among the announced or reported regional hub locations under the reorganization:
- Raleigh, North Carolina
- Kansas City, Missouri
- Indianapolis, Indiana
- Fort Collins, Colorado
- Salt Lake City, Utah
This geographic dispersal of USDA leadership and program staff represents a significant structural shift for the department. For regulated businesses, the practical concern is that shutdown contingency plans — which depend on clear command structures and rapid decision-making authority — are inherently harder to execute during a period of active reorganization, particularly when institutional knowledge and leadership lines are in transition.
Workforce Changes: What Official Sources and Reports Indicate
USDA has experienced workforce reductions during 2025–2026. Based on USDA's own public disclosures, Congressional testimony, and widely reported news accounts, the department has seen a substantial reduction in full-time employees across multiple agencies. Among the reported impacts:
- APHIS: Public reporting and agency sources indicate significant workforce reductions — widely cited as among the largest percentage reductions of any USDA sub-agency. Given that APHIS retained 54% of employees during the October 2025 shutdown, any reduction in its total workforce baseline reduces the absolute number of employees available for export certification, emergency disease response, and border surveillance during a future lapse.
- FSIS: Agency reporting indicates FSIS has also experienced staffing reductions. The 89% retention rate that held during October 2025 would produce fewer total inspectors in absolute terms if the agency's workforce baseline declines, raising longer-duration capacity questions.
- FSA: Already the most severely impacted agency during shutdowns at 24% retention, FSA's operational capacity during a future lapse depends directly on its staffing levels at the time of any funding gap.
Note: Specific workforce reduction figures are the subject of ongoing reporting, Congressional inquiry, and agency disclosure. OFW attorneys recommend verifying current staffing levels through official USDA reports, OPM workforce data, or Congressional Budget Office testimony rather than relying on any single news source for compliance planning purposes.
What This Means for Compliance Planning
The combination of active workforce changes and geographic reorganization creates planning considerations that did not exist in prior shutdowns. Several specific implications stand out for regulated businesses:
- Reduced employees available for "excepted" designation: When a shutdown occurs, agencies designate employees as "excepted" if their work is necessary to protect life or property under the Anti-Deficiency Act. With a reduced total workforce, USDA has fewer employees to designate — meaning some functions that continued during October 2025 may not be fully covered during a subsequent lapse at the same scale.
- Uncertainty during active reorganization: Policy decisions during a shutdown require clear institutional authority. A department actively relocating staff and restructuring reporting lines faces additional coordination challenges during a funding lapse that a fully stable agency does not.
- Animal disease response capacity questions: To the extent APHIS staffing has declined, the agency's ability to maintain the breadth of emergency disease response it provided during October 2025 may warrant monitoring as a planning assumption rather than a guarantee.
For food manufacturers and importers, these changes mean that contingency planning for upcoming shutdowns should not assume October 2025 experience is fully replicable. Understanding which agency — FDA or USDA — holds jurisdiction over your products is foundational for determining which compliance obligations remain active and which may be affected by USDA capacity changes during a funding lapse.
Shutdown Duration Timeline: What Changes and When
USDA agencies adjust operations based on shutdown duration, with specific thresholds triggering staff recalls and expanded services. The October 2025 shutdown provided real-world data on how these thresholds play out at 43 days. The table below incorporates actual October 2025 operational data alongside the standard duration framework.
| Shutdown Duration | FSA Actions | FSIS Actions | APHIS Actions | Business Planning Considerations |
|---|---|---|---|---|
| Days 1–5 — Initial Shutdown Period | Leadership on-call only for CCC security and natural disaster response; county offices closed | Normal inspection operations continue without disruption | Emergency disease programs only; routine services suspended | Monitor for quick resolution; maintain normal operations where inspection continues; begin documenting compliance activities with dates |
| Days 5–10 — Reconsideration Threshold | Agency evaluates need for staffing adjustments; no loan processing available | No operational changes; label approval backlog accumulating | Staff recall evaluation for critical trade issues; export certificate delays growing | Prepare for potential service expansions; document all compliance efforts; assess alternative financing if FSA-dependent |
| Days 10+ — Extended Shutdown | One farm loan employee per service center on-call; disaster payment suspension continues | Continued normal operations; state program funding reserves being drawn down | Possible expanded operations for accumulating trade backlogs | Implement alternative compliance strategies; consult regulatory counsel on open policy questions |
| Day 23 — FSA Partial Reopening (Oct 2025) | County offices partially reopen; ARC/PLC payment processing resumes; priority loan processing restored | Inspections continue; label reviews still suspended | Emergency disease response maintained throughout | FSA borrowers: confirm loan status and payment processing timelines with your district office |
| Days 30+ — Critical Threshold | Further staffing evaluation; expanded emergency protocols under consideration | State program funding exhaustion risk increasing | Trade disruption escalates; international partner concerns increasing | Prepare for 4–8 week backlog recovery period after resolution |
| Days 43+ Resolution — November 12, 2025 | Full operations resume; significant loan application and disaster payment backlog to clear | Full operations resume; label approval and policy guidance backlogs process over several weeks | Full operations resume; export certificate backlog begins clearing | Submit time-sensitive applications immediately upon reopening; expect extended processing timelines for 4–6 weeks post-resolution |
Source: USDA's published contingency planning and lapse documentation; USDA FY 2026 Lapse of Funding Plan; October 2025 shutdown operational data
Historical context: Prior to October 2025, the longest U.S. government shutdown was the 2018–2019 closure at 35 days. The October 2025 shutdown exceeded that by eight days, providing the most detailed real-world dataset available on extended USDA operational management during a funding lapse.
APHIS Services During Government Shutdowns
The Animal and Plant Health Inspection Service maintains many functions during shutdowns because user fees and emergency funding support its critical operations. APHIS's approach reflects its dual role in facilitating agricultural trade and protecting against animal and plant health emergencies — two functions with very different funding structures and shutdown treatment. Businesses engaged in international food trade and distribution depend heavily on user-fee funded APHIS services during any funding lapse.
Operations Funded by User Fees
APHIS continues these services without interruption because businesses pay fees that cover operational costs independently of annual appropriations:
- Agricultural Quarantine Inspections at ports of entry
- Animal import and export certification services
- Issuance of phytosanitary certificates for plant exports
- Border surveillance and inspection activities
- Work funded through reimbursable agreements with states and cooperators
These user-fee services remained available throughout the October 2025 shutdown to support international trade flows and maintain export market access for agricultural products, though processing timelines lengthened as the shutdown extended.
Emergency Response Programs
APHIS emergency programs continue operating using emergency fund balances and contingency reserves. During the October 2025 shutdown, the agency maintained active responses to highly pathogenic avian influenza outbreaks, New World Screwworm emergency programs, African swine fever prevention and surveillance, and protection of federal lands from agricultural pests. These responses continued without interruption throughout the 43-day closure.
Suspended Activities
APHIS halts operations that rely entirely on annual appropriations during a funding lapse. This includes routine animal welfare inspections under the Animal Welfare Act, Horse Protection Act enforcement, and certain cattle and swine health programs. For businesses regulated under these programs, shutdown periods create compliance gaps and delayed inspections that can create backlogs extending weeks beyond the shutdown resolution.
Agricultural Marketing Service Functions and Funding Sources
The Agricultural Marketing Service maintains most operations during shutdowns because user fees and mandatory funding sources support its core services. AMS provides grading, inspection, and market information services that facilitate agricultural commerce — most of which are insulated from appropriations lapses by their fee-based funding structure.
Services That Continue
User-fee funded AMS activities proceed without interruption during a government shutdown:
- Grading services for cotton, dairy, poultry, and meat products
- Inspection and certification of seeds and specialty crops
- Perishable Agricultural Commodities Act (PACA) licensing and enforcement
- Market News reporting and price discovery information
- Laboratory testing and quality verification services
These services continue because businesses pay fees that fully cover operational costs, making them independent of annual Congressional appropriations.
Programs That Shut Down
Several key AMS regulatory programs cease during funding lapses. The October 2025 shutdown suspended the National Organic Program certification and enforcement activities, Country of Origin Labeling compliance, and National Bioengineered Food Disclosure Standard enforcement — for the full 43-day duration. The Packers and Stockyards Program — which enforces fair trade protections for cattle sellers and livestock market participants — also halted enforcement activities during the shutdown.
The USDA's shutdown plan specifically noted that National Organic Program suspensions lasting more than a few days would significantly impact the organic industry. The October 2025 shutdown confirmed that warning: certification agencies and certified operations faced substantial delays in applications, renewals, and compliance review — backlogs that took several weeks to clear after November 12.
For businesses operating under these regulatory programs, shutdown periods require careful attention to compliance deadlines and certification renewals. Our USDA regulatory practice assists clients with compliance strategy during government disruptions and helps manage regulatory risk when oversight programs suspend operations.
Farm Service Agency: Loans, Payments, and Disaster Aid
The Farm Service Agency is the USDA component most severely affected by government shutdowns. With only 24% of its workforce designated as excepted under contingency plans, FSA effectively closes most county service centers at the start of any funding lapse. For agricultural borrowers, FSA-dependent operators, and disaster assistance recipients, the October 2025 experience established important operational benchmarks.
What Happened During October 2025
From October 1 through October 22, FSA county offices were closed. Farm loan servicing halted. Direct loan applications were not accepted. Guarantee commitments were suspended. Disaster assistance payments under SDRP, ELRP, and ECAP programs stopped processing. For agricultural operations dependent on timely FSA payments or credit access, this represented a 22-day gap in financial services infrastructure that rural operations rely on at fiscal year-end.
On October 23, 2025 — day 23 of the shutdown — FSA partially reopened county offices with limited staff. This partial resumption allowed:
- ARC/PLC payment processing to resume for enrolled producers
- Core loan processing functions to restart for time-sensitive cases
- County office staff to address accumulating case backlogs in limited capacity
Full FSA operations did not restore until November 12. Agricultural borrowers facing loan deadlines between October 1 and October 22 had no recourse through normal FSA channels during that period.
Preparing for FSA Disruptions Before October 1, 2026
FSA's contingency structure means any government shutdown immediately disrupts agricultural lending, disaster payments, and most county office functions. The practical preparation steps for agricultural operators before any potential funding lapse:
- Complete pending loan applications well before September 30 to avoid shutdown timing conflicts
- Confirm disaster payment status for pending SDRP, ELRP, or ECAP claims before the fiscal year transition
- Identify alternative short-term financing that does not depend on FSA processing timelines
- Document all pending FSA interactions with date-stamped correspondence in the event of disputes over timeline compliance
- Review loan agreements for any provisions addressing government shutdown delays and your lender's policies on shutdown-related grace periods
Business Impact Checklist: What Your Company Should Do Now
USDA is fully funded through September 30, 2026, which means food and agriculture businesses have a defined window to act before the next potential funding lapse opens October 1, 2026. The October 2025 shutdown created documented operational disruptions that companies can prepare for systematically. This checklist addresses pre-shutdown, during-shutdown, and documentation priorities by business category.
- Submit pending label change requests before September 30
- Confirm FSIS inspector assignment continuity plan
- Resolve open policy questions with FSIS district office
- Maintain detailed HACCP records during any lapse
- Defer non-critical label changes until post-shutdown
- Build buffer stock of phytosanitary certificates before Sept 30
- Confirm APHIS user-fee service availability for priority markets
- Notify foreign buyers of potential certificate processing delays
- Review export contracts for force majeure provisions
- Document all APHIS correspondence with submission dates
- Submit NOP certification renewals well before September 30
- Compile pending compliance questions for pre-shutdown resolution
- Review certification renewal calendar for Q4 timing exposures
- Document all decisions thoroughly with legal basis cited
- Monitor renewal deadlines with heightened attention
- Complete pending FSA applications before September 30
- Identify short-term alternative financing not dependent on FSA
- Confirm disaster payment status for all pending claims
- Review loan agreements for shutdown provisions and grace periods
- Build financial hardship evidence file from day one of any lapse
| Business Type | Pre-Shutdown Actions (Before Oct 1, 2026) | Actions During a Shutdown | Compliance Documentation |
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| Meat/Poultry Processor |
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| Organic Certifier/Producer |
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| Agricultural Lender/Borrower |
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| SNAP-Authorized Retailer |
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For businesses with open compliance questions across any of these categories, now is the optimal period to get regulatory guidance in place before the next potential shutdown window. Our food and agriculture compliance risk management team can help you identify your specific exposure points before October 1, 2026.
When to Consult a USDA Regulatory Attorney
Most food and agriculture businesses can manage routine shutdown-related compliance questions with careful documentation and proactive planning. However, certain situations call for specialized legal counsel — particularly given the new variables that workforce changes and USDA reorganization have introduced into the agency's operational picture.
Consider consulting a USDA regulatory attorney when:
- Label approval backlogs are affecting production timelines. When FSIS label reviews are suspended during a shutdown and you are operating under previously approved labels with pending amendments, maintaining a defensible compliance position requires specific documentation strategies that depend on your product category and the nature of the pending change.
- NOP certification timelines were disrupted by the October 2025 shutdown. The 43-day NOP suspension created certification gaps that some organic producers may still be resolving. Legal counsel can help document good-faith compliance and address any enforcement exposure tied to shutdown-caused delays.
- Export certificate delays created contract compliance issues. If APHIS processing delays caused you to miss export contract deadlines during October 2025, the legal implications depend on your specific contract terms, the force majeure provisions in place, and the documentation maintained during the delay period.
- You are facing USDA enforcement actions related to activities during or immediately following a shutdown period. Defending USDA enforcement actions when the underlying compliance question arose during a period of suspended agency oversight involves specific procedural and substantive considerations.
- FSA loan or disaster payment disputes remain unresolved from the October 2025 shutdown period. Agricultural borrowers who experienced payment disruptions during the 22-day county office closure may have documentation and dispute resolution needs that benefit from attorney assistance.
- You are planning operations that depend on USDA regulatory timelines in the Q3–Q4 2026 period. Any transaction, product launch, or certification requiring USDA approvals with a deadline near October 1, 2026 warrants contingency planning now.
OFW attorneys maintain direct working relationships with officials across FSIS, APHIS, AMS, and FSA. That institutional access matters when shutdown-related compliance questions require answers that cannot come from published agency guidance — or when an agency is operating at reduced capacity and response times are extended. Contact our USDA regulatory team to discuss your specific compliance situation before the next potential shutdown window opens.
Frequently Asked Questions
Preparing Now for the Next Potential Shutdown
USDA is fully operational today, but October 1, 2026 is a fixed deadline. With the agency undergoing active workforce and structural changes, food manufacturers, importers, and agricultural businesses that experienced the October 2025 shutdown should use this window to strengthen their compliance positions before the next potential lapse.
The priorities are clear: thorough documentation of current compliance status, deadline management that submits time-sensitive applications well before September 30, and direct access to legal counsel for questions that depend on USDA policy guidance. Get those answers now — while the agency is staffed, the offices are open, and policy officials can respond.
If you need specialized guidance on navigating USDA regulatory requirements during government shutdowns, or have unresolved compliance questions stemming from the October 2025 closure, reach out to the OFW Law team for expert regulatory representation. Our attorneys work directly with USDA officials across FSIS, APHIS, AMS, and FSA — institutional access that matters most when agency operations are constrained and compliance timelines leave no room for delayed answers.