“A continued downward trend in import volumes, which is driving tighter assessment of accessorial fees as ports seek to capture revenue during peak season,” has been confirmed by ITS Logistics’ recently released October forecast for its US Port/Rail Ramp Freight Index. “Outside the ports, the evolving regulatory situation surrounding non-domiciled CDLs is driving lower-cost capacity out of the market, increasing the risk of financial insolvency for some carriers. These compounding factors are placing a downward squeeze on an already soft drayage market, which could cause problems for shippers in both the short and long term.”
ITS Logistics, a Nevada-based third-party logistics (3PL) firm, releases each month an index forecasting port container and dray operations for the Pacific, Atlantic and Gulf regions; ocean and domestic container rail ramp operations are also highlighted for both the West and East inland regions.
“Terminals and rail ramps should not face any major challenges due to inbound or export volumes,” said ITS Logistics Vice President of Global Supply Chain Paul Brashier. “There are, however, some storm clouds on the horizon that could negatively impact trucking and, by extension, terminal and port operations upstream.”
On Sept. 26, following the review of findings from a nationwide audit of CDL licenses, the Federal Motor Carrier Safety Administration (FMCSA) issued an emergency interim ruling restricting eligibility for non-domiciled CDLs. In response, several states have implemented enforcement efforts to verify CDL compliance and English language proficiency (ELP) at weigh stations, ports of entry, and along major transportation routes, according to ITS Logistics. “Industry experts warn that non-domiciled CDL holders account for a significant portion of the lower-cost capacity market and that regulatory crackdowns will likely result in a surge in bankruptcies across small and mid-size carriers. This is especially true for the drayage market, which has seen multiple major providers close their doors throughout 2025. It is anticipated that stricter enforcement of non-domiciled CDLs and ELP requirements will exacerbate financial challenges, pushing out capacity and ultimately impacting terminal and port operations.”
“In the near term, these new regulations will remove capacity from the ecosystem and cause market disruption,” Brashier continued. “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. Vetting service provider health will become even more important as shippers begin late 2025 and early 2026 RFP activity.”
U.S. September import volume is projected at 2.12 million TEUs, down from 2.28 million TEUs in August and representing a 6.8% year-over-year decrease, according to ITS Logistics report. “The National Retail Federation anticipates that monthly import volumes will continue to drop for the remainder of the year, citing tariffs and frontloading activity in the first half of 2025. In response to low container demand and declining per-container revenue, ocean carriers are strictly enforcing their accessorial schedules to maintain profitability. With minimal exceptions beyond clear operational failures, ITS Logistics recommends shippers review their supply chains for any inefficiencies that could be exposed and penalized under this renewed focus.”
“Shippers should take this opportunity to confirm that accessorial dispute processes and documentation requirements are clearly defined in their SOPs,” Brashier said. “If your supply chain utilizes rail for ocean container movement, it’s also important to ensure you understand items like chassis pool flip policies and which parties to engage with to resolve issues within free time.”
