Insights

E&E News reported that EPA will continue to operate during the shutdown relying on “carryover funds.” Carryover funds generally are unspent and unobligated funds from a previous budget period that are carried forward to cover allowable costs in a future budget period. There is no indication how long EPA’s carryover funds will allow all EPA employees to continue working versus those that are “exempted” or “excepted” personnel, meaning they can continue to work either because they are separately funded (“exempted) or must continue to work because of their position (“excepted), such as emergency responders or criminal agents.

As of midnight on September 29, 2025, the U.S. government has entered a shutdown, triggering furloughs across many agencies that regulate the import and export of wildlife and wildlife products. For businesses and organizations engaged in international wildlife trade, this development raises urgent questions about inspections, permitting, and compliance. These delays impact not only entities engaged in the transfer of live animals but also companies involved in selling products in brick-and-mortar stores as well as e-commerce online stores, covering everything from food, jewelry, skincare and cosmetics to art supplies, home décor and furniture – many of which contain imported or exported wildlife products. 

On September 24, 2025, the California Air Resources Board (“CARB”) issued a preliminary list of reporting/covered entities under California’s climate disclosure laws SB 253 (the Climate Corporate Data Accountability Act) and SB 261 (the Climate-Related Financial Risk Act) (the “Climate Disclosure Laws”) (both as modified by SB 219).