Today’s cold chain is operating in a changing world. Lasting impacts of the pandemic and geopolitical unrest have led to changes in global trading relationships, with further shifts anticipated under President Trump’s second term. At the same time, nations, consumers, and supply chains alike are navigating the advent of AI, economic and political uncertainties, fast-changing populations, extreme weather events, and increasing focus on sustainability.
In the United States, this time of transition is accompanied by several policy changes that, if enacted, will have a range of impacts for temperature-controlled logistics operations. Up-to-date awareness of the policies under consideration and their progress can help cold chain operators not only prepare for the potential challenges ahead, but also identify opportunities and explore how to harness them.
Fortifying refrigeration infrastructure
As GCCA considers the policy outlook for 2025, a high priority within GCCA’s advocacy work remains the advancement of the FRIDGE (Fortifying Refrigeration Infrastructure and Developing Global Exports) Act and its inclusion in the next Farm Bill. The legislation would add authority to the Trade Title of the Farm Bill to focus on strengthening the global food supply chain for frozen and refrigerated products. The FRIDGE Act would strengthen the ability of emerging markets to safely and efficiently receive high-quality U.S. perishable commodities. This would create new trade opportunities, improve food security and nutrition, and reduce waste due to food loss.
The FRIDGE Act has bi-partisan support and was included in both the House and Senate versions of the Farm Bill in 2024. However, disagreements on nutrition and conservation policy slowed Farm Bill progress and Congress is preparing a one-year extension of the 2018 Farm Bill to allow time in 2025 to complete a new bill. GCCA continues to work closely with senators and representatives to promote the continued inclusion of the FRIDGE Act as the Farm Bill process moves forward.
Food safety
Cold chain operators should also be aware of the current compliance deadline of January 2026 for the Food Safety Modernization Act (FSMA) Food Traceability Rule (204 Rule). This rule requires traceability recordkeeping beyond those in existing regulations and concerns have been increasing that compliance will be unnecessarily burdensome. GCCA, along with food industry partners, has been calling for a delay of the compliance deadline to enable FDA to work further with industry on pilot programs to identify effective compliance strategies.
The Food Traceability Enhancement Act, introduced in 2024, aimed to reduce the recordkeeping requirement from two years to one year, and to eliminate the requirement for certain establishments (including warehouses) to maintain or provide lot codes. The act requires the Food and Drug Administration (FDA) to conduct pilot projects to assess outbreak investigation methods and tracing technologies, and extends the compliance date of the rule to at least two years after the completion of the pilot projects. The Food Traceability Enhancement Act has bipartisan support and elements of the legislation are included in both House and Senate versions of the 2025 Agriculture Appropriations Bill. GCCA will continue working with FDA, Congress, and industry to address issues related to this rule in 2025.
Biden-era rollbacks
The Trump administration is expected to pursue deregulation across many federal agencies. Rolling back burdensome regulations was a priority for Trump in his first administration and that work is likely to continue in his second term. An additional element to the incoming administration will be the effort led by Elon Musk and Vivek Ramaswamy to establish a Department of Government Efficiency. Not many details are known as to how the new organization will operate, but both Musk and Ramaswamy have talked about the need to evaluate and pare back the current regulatory framework.
Trump has indicated that he will take aim at a number of Environmental Protection Agency (EPA) regulations and policies adopted by the Biden Administration. In his first term, Trump moved to reconsider Risk Management Program (RMP) changes finalized by the Obama administration. It is possible that history will repeat itself with the recent RMP changes instituted by the Biden administration. The latest RMP Rule, “Safer Communities by Chemical Accident Prevention” was finalized in February 2024, but the compliance date for most provisions is not until 2027. The new EPA leadership could consider additional rulemaking to revise or rescind the Biden-era RMP rule.
Climate-related regulations will be another target of a Trump administration EPA. Expect shifts away from Biden-era climate policies and regulations, including potential withdrawal from international efforts such as the Paris Climate Agreement. The fate of American Innovation and Manufacturing (AIM) Act regulations to phase down the use of HFCs is uncertain. The AIM Act passed with bipartisan support and has support from some in industry, so it is unclear where addressing these policies will be on EPA’s priority list for change under Trump.
Policy transitions and uncertainty
Trade and tariffs will be a high priority for the Trump administration and could have a significant impact on the cold chain and international flow of perishables. Trump has been clear about his intentions to explore additional tariffs on foreign goods and promoting domestic production. This could strain relationships with some trading partners and result in retaliatory tariffs or other actions against U.S. goods. Food and agriculture products are usually high on the list of retaliatory options for trading partners, which could impact U.S. food and agriculture exports. In addition to tariffs, a review of key trade agreements is also likely to occur during Trump’s second term. USMCA (formerly known as NAFTA) is scheduled to undergo a review in 2026 and each of the countries is preparing for domestic consultations to evaluate how USMCA is operating. Trump has already signaled his intention to utilize the six-year renegotiating provision under USMCA to revise the agreement.
Looking ahead to the coming year, there remains some uncertainty about how these proposed changes will be advanced. Overall, we can expect moves to reduce the burden and cost of regulations for businesses, particularly with the establishment of the new Department of Government Efficiency and the likely shift in the focus of key regulatory agencies. The potential institution of additional tariffs on imported products could have a range of impacts on the food supply chain, such as reducing impact export opportunities for some commodities while encouraging nearshoring and increasing demand for domestic freight.
Amid the policy transitions and uncertainty, it will be imperative to advocate on behalf of the cold chain and demonstrate the critical role it plays in ensuring a safe, reliable, and efficient food supply. GCCA will continue to ensure policy makers have a robust understanding of how proposed legislative and regulatory changes will impact the cold chain, and the effects of these changes on our important roles for the economy, our communities, and the food supply chain.
