Freight Pulse & Law Update: FMCSA Pauses USDOT Deactivations, CBP Opens Tariff Refund Phase Three : What Shippers Must Know
FMCSA has paused enforcement of biennial MCS-150 updates and USDOT deactivations for deadlines on or after June 1, 2026, during the MOTUS transition. CBP will open tariff refund phase three on October 6, 2026, for court-ordered refunds on finally liquidated entries. Importers and carriers should reconcile records now, not treat either measure as permanent relief.
What changed for motor carriers?
The FMCSA official notice confirms that carriers do not need to file overdue updates immediately to avoid deactivation during this window. However, the biennial obligation remains. Monitor FMCSA registration alerts and prepare current information for filing.
Relief applies to deadlines falling on or after June 1, 2026.
MOTUS enforcement is paused until further notice.
Intrastate carriers no longer have a federal biennial filing option in MOTUS; states may impose separate requirements.
What should importers do before October 6?
According to MLex reporting on CBP’s declaration to the Court of International Trade, phase three covers finally liquidated entries subject to a court order. CBP says it has processed more than $134 billion in refunds and sent approximately $122 billion to Treasury for payment.
Importers should:
Reconcile eligible entries and court orders.
Confirm ACH refund routing and broker-of-record data.
Review Form 5106 information before CBP’s September 18 enforcement date, when inaccurate or incomplete records may void an Importer of Record number without a cure period.
Why does compliance affect delivery performance?
CVSA’s Brake Safety Week schedule places the 2026 enforcement push on August 23–29. Treat it as a year-round standard: brake out-of-service violations can damage CSA scores and disrupt on-time delivery for third party logistics providers. The same discipline applies across a food-grade warehouse, Hazmat certified 3PL, and Mid-Atlantic fulfillment network.

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