USTR Expands Section 301 Tariffs in Maritime & Logistics Sectors

On October 14, 2025, the U.S. Trade Representative (USTR) implemented new service fees on vessels that are Chinese-built, owned, or operated, to be collected upon arrival at U.S. ports. Last Friday, the USTR announced revisions and expansions to these Section 301 measures targeting China’s maritime, logistics, and shipbuilding sectors. The latest actions introduce revised fee structures, confirm a November 9, 2025 implementation date for previously announced tariffs, add new tariff targets on cargo-handling equipment, and remove a prior LNG licensing suspension. Additional proposed modifications are open for public comment through November 10, 2025.

For clients of Western Overseas, these developments warrant attention as they may affect shipping operations, cargo handling, and logistics planning. This article outlines the new measures, considers their operational impact, and offers strategic considerations for your supply chains.

Operational Impacts

Some ocean carriers have issued notices indicating that they do not plan to implement a related surcharge, directly passing the new fees to customers. Instead, several have signaled intentions to reorganize vessel rotations in order to minimize how frequently these fees are triggered.

Under the new framework, U.S. Customs and Border Protection (CBP) will be responsible for collecting the fees as directed by the USTR, while vessel agents or operators must determine the applicable fee or exemption, remit payment, and provide supporting documentation to CBP.

There is ongoing concern about the operational impacts of these rotation adjustments and the reported uncertainty among vessel agents regarding how fees, exemptions, and related proof will be administered. If a required fee is not properly paid or exemption documented, CBP may deny the vessel entry, directly affecting import schedules and potentially causing downstream delays for export shipments.

While carriers may initially absorb these costs, it is reasonable to expect that they will continually assess the impacts of these fees and may change their initial course of action.

Summary of the Annexes (Including Newly Announced Changes)

Annex I – Service Fees on Chinese Vessel Operators and Owners

• Applies to Chinese-owned or operated vessels arriving at U.S. ports.
• Fees per net ton*:
  • $50 (Oct 14 2025) → $80 (Apr 17 2026) → $110 (Apr 17 2027) → $140 (Apr 17 2028).
• Capped at five assessments per vessel, per year.
• Fees apply per rotation or “string” of U.S. port calls.

Annex II – Service Fees on Chinese-Built Vessels

• Applies to vessels built in China, regardless of operator nationality, effective October 14, 2025.
• Two calculation methods — operator pays the higher of:
  • Per net ton*: $18 → $33 (phased 2025–2028), or
  • Per container: $120 → $250 (phased 2025–2028).
• Capped at five assessments per year, per vessel.
• Exemptions:
  • U.S.-flagged or U.S.-owned vessels;
  • Vessels in national security programs;
  • Ships arriving empty, in ballast, or under 2,000 nm voyages;
  • Smaller vessels (≤ 4,000 TEUs, ≤ 55,000 DWT general cargo, ≤ 80,000 DWT bulk).
• Also includes incentives for ordering U.S.-built ships.

Annex III – Service Fee on Foreign-Built Vehicle Carriers

• Applies to non-U.S.-built vehicle carriers (e.g., Ro-Ro ships).
• Fee of $46 per net ton” effective October 14, 2025, replacing the earlier “car-equivalent-unit” method.
• Capped at five times per year, per vessel.
• Exemptions:
  • U.S.-flagged vessels in the Maritime Security Program (expires April 18, 2029).
  • U.S. Government vessels.
• Clarifies “vehicle carrier” to include Ro-Ro cargo types.

Annex IV – LNG Export Vessel Requirements

• Establishes a graduated requirement that LNG exports move increasingly via U.S.-built, flagged, and operated vessels beginning April 17, 2028.
• Vessels ordering and taking delivery of new U.S.-built LNG ships can receive three-year exemptions.
• The prior rule allowing suspension of LNG export licenses has been removed retroactively to April 17, 2025, avoiding trade disruption while promoting U.S. shipyard investment.

Fee hierarchy:

1. LNG vessels (Annex IV) stand apart.
2. Vehicle carriers → Annex III.
3. Chinese-owned → Annex I.
4. Chinese-built → Annex II.
   Fees are not cumulative.

Annex V – Tariffs on Ship-to-Shore Cranes and Cargo-Handling Equipment

• Implements 100% tariffs, effective November 9, 2025, on:
  • Ship-to-shore cranes of Chinese origin or influence.
  • Intermodal chassis and chassis parts (HTS 8716.39, 8716.90).
• Exemptions: STS cranes contracted before April 17, 2025, and entering by April 18, 2027.
• No new duty on intermodal containers (a key change from April’s proposal).
• Proposed expansion (Annex V-B): additional tariffs up to 150% on port handling gear such as gantry cranes, reachstackers, straddle carriers, terminal tractors, and top loaders.

* Note: Net tonnage is based on the vessel’s net tonnage (internal capacity) as opposed to cargo net tonnage.

For more information, contact your Western Overseas representative.