Low Import Volumes Drive Tighter Assessment of Non-Domiciled CDLs

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.

Marina M Headshot
Carolyn Franks Adobe Stock 157451465
Carolyn Franks AdobeStock_157451465

ITS Logistics’ recent US Port/Rail Ramp Freight Index confirms a continued downward trend in import volumes, driving tighter assessment of accessorial fees as ports seek to capture revenue during peak season.

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.

“Terminals and rail ramps should not face any major challenges due to inbound or export volumes,” says Paul Brashier, VP of global supply chain for ITS Logistics. “There are, however, some storm clouds on the horizon that could negatively impact trucking and, by extension, terminal and port operations upstream.”

Key takeaways:

 

·        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.

·        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. 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.

“In the near term, these new regulations will remove capacity from the ecosystem and cause market disruption,” Brashier adds. “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.”

Page 1 of 111
Next Page