FMI – The Food Industry Association (FMI) welcomes the opportunity to comment on the Request for Information (RFI) on Protecting America’s Supply Chain from Cargo Theft (Docket No. DOT-OST-2025-1326). The threat environment facing the food industry has evolved into a complex tapestry of domestic and transnational challenges – with cargo theft being one of many.

The risks of cargo theft in the food and consumer goods supply chain are multifaceted. For example, organized crime syndicates use sophisticated methods to perpetrate cargo theft and other retail crimes. These domestic and transnational syndicates and other bad actors use digital tools to steal or buy carrier credentials, gain access to email and shipping and cargo management systems, and falsify dispatches to reroute shipments or double broker a load. Other actions that lead to cargo theft include the manipulation of bill of lading (BOL) and paperwork, and carriers consolidating loads and failing to maintain chain of custody in violation of agreements. Cyber-enabled diversion, such as GPS spoofing, and other cyber threats also pose significate risks. As technologies continue to advance so does the ability for crime syndicates and bad actors to expand their reach.

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