Freshspective

OCEAN TRENDS - Global ocean networks continue to normalize, although operating conditions remain fluid and regionally uneven. The security situation in the Red Sea, Bab el-Mandeb Strait, and broader Middle East continues to influence carrier network decisions and routing strategies. During 2026, several major carriers, including Maersk, MSC, CMA CGM, Hapag-Lloyd, and COSCO, have progressively expanded Suez Canal utilization on selected services following ongoing improvements in regional security conditions. Additional Asia-Europe and Asia-Mediterranean services were restored to Suez routing during September 2026; however, carriers continue to characterize these routing decisions as conditional and subject to reversal should security conditions deteriorate. Overall Suez Canal traffic has improved from 2025 levels but remains significantly below pre-crisis volumes, with many operators maintaining contingency routings via the Cape of Good Hope. Recent increases in containership transits suggest improving confidence, but war-risk insurance costs, operational flexibility concerns, and periodic security incidents continue to limit a full network return to pre-2024 operating patterns. Transit times have improved on services returning to Suez routing; however, vessels continuing to utilize Cape routings may still experience voyage extensions of approximately 10 to 14 days. Carriers remain disciplined in capacity deployment, while equipment imbalances and periodic space constraints continue to occur in select trade lanes. Reefer demand remains robust in several agricultural export markets, particularly in Latin America, and equipment repositioning challenges continue to affect refrigerated cargo availability in certain regions.

TARIFF IMPACTS - The U.S. tariff environment remains highly dynamic and continues to present significant compliance and cost-management challenges for importers. The temporary Section 122 import surcharge expired on July 24, 2026, upon reaching its statutory 150-day limit. Simultaneously, the Office of the U.S. Trade Representative (USTR) implemented new Section 301 tariff measures applicable to approximately 60 economies, establishing a two-tier tariff structure generally ranging from 10 percent to 12.5 percent. As a result, many importers have experienced little overall reduction in duty exposure despite the expiration of the Section 122 surcharge, as the new Section 301 measures largely replaced the temporary surcharge framework. Existing Section 301, Section 232, antidumping, and countervailing duty programs remain in effect, and additional trade actions continue to be evaluated under multiple statutory authorities. Importers should continue monitoring developments closely, as trade policy remains subject to ongoing regulatory, judicial, and administrative developments.

DEMURRAGE/DETENTION CHARGES - Following the September 23, 2025 decision by the U.S. Court of Appeals for the District of Columbia Circuit in World Shipping Council v. Federal Maritime Commission, the Federal Maritime Commission (FMC) ceased enforcement of 46 CFR Section 541.4, the provision governing which parties may be invoiced for demurrage and detention charges. The FMC subsequently removed Section 541.4 from the Code of Federal Regulations. The court vacated only that section of the rule and left all remaining Demurrage and Detention Billing Requirements fully intact. Accordingly, invoice-content requirements, the 30-day invoice issuance deadline, and associated billing dispute timelines remain enforceable. The FMC has indicated that future rulemaking may address invoicing responsibility; however, no replacement regulation has been finalized as of September 2026. As a result, contractual provisions and commercial agreements currently remain the primary mechanisms governing responsibility for demurrage and detention charges. Stakeholders should continue reviewing contractual allocations of demurrage and detention liability and ensure billing practices align with the remaining requirements of 46 CFR Part 541.

REGULATORY & COMPLIANCE LANDSCAPE - The FDA continues implementation activities associated with the Food Safety Modernization Act (FSMA) Section 204 Food Traceability Rule. The compliance deadline remains July 20, 2028. Although enforcement remains deferred, FDA has continued conducting stakeholder outreach, public meetings, tabletop readiness exercises, and discussions regarding potential implementation flexibilities, particularly concerning lot-level traceability requirements. During 2026, FDA conducted additional stakeholder engagement activities and released supplemental implementation materials focused on compliance flexibilities and industry readiness. Many retailers, foodservice providers, and supply chain partners continue advancing traceability initiatives ahead of the compliance deadline and may require enhanced recordkeeping and electronic data-sharing capabilities before federal enforcement begins. Companies handling Food Traceability List products should continue preparing for compliance despite the extended implementation timeline.

ISPM-15 WOOD PACKAGING PROTOCOLS (UPDATED 2026) - Effective January 1, 2026, USDA APHIS and U.S. Customs and Border Protection (CBP) resumed full enforcement of the ISPM-15 hyphen requirement contained within the IPPC wood packaging mark. The agencies previously suspended enforcement during much of 2025 but confirmed there would be no additional grace period or soft-enforcement period following December 31, 2025. Shipments containing noncompliant wood packaging materials may be subject to cargo holds, re-export requirements, penalties, or other enforcement actions. Importers and exporters should ensure all wood packaging materials fully comply with ISPM-15 marking requirements, including the required hyphen separating the country code from the producer code, in order to avoid potential supply chain disruptions.

EMERGENCY BUNKER SURCHARGE - Emergency bunker, fuel, war-risk, security, contingency, and conflict-related surcharges continue to impact global ocean transportation costs. Although portions of the container shipping industry have cautiously resumed Red Sea and Suez Canal transits, many carriers continue to apply war-risk and contingency-based pricing mechanisms due to ongoing geopolitical instability, elevated insurance premiums, and operational uncertainty in the Middle East. Recent security incidents and periodic disruptions in the Red Sea, Gulf region, and adjacent waterways continue to create uncertainty regarding transportation costs, transit times, schedule reliability, and network planning. While freight markets remain generally balanced, carriers maintain the flexibility to adjust surcharge programs rapidly in response to security developments, insurance market conditions, fuel costs, and vessel-routing decisions. Importers and exporters should continue monitoring carrier advisories closely, as war-risk and conflict-related surcharges may be implemented, modified, or withdrawn on short notice.