October 14, 2025, will mark a pivotal date when the Office of the United States Trade Representative (USTR) officially enacts new fee policies targeting vessels built or operated by Chinese entities. Following a year-long investigation and public consultation process, the revised policy shows significant modifications from its initial proposal, with notable changes in both content and potential impact.
The adjusted fee structure, developed in response to concerns about international trade fairness, represents a more moderate approach compared to the February 21 preliminary proposal. The most substantial change replaces the original "per port" fee with a "per U.S. voyage" charge, directly reducing the financial burden on shipping companies. Additionally, the revised version exempts certain carriers that would have been affected under the original plan, increasing flexibility for the industry.
According to USTR's announcement, the agency collected over 600 comments from shipping companies, port authorities, and agricultural groups during its year-long Section 301 investigation. This extensive feedback allowed for more precise policy formulation regarding the fee implementation.
Key Policy Annexes and Their Implications
Annex I: Fees for Chinese-Owned/Operated Vessels
This section introduces tonnage-based fees for U.S. voyages by vessels owned or operated by Chinese companies. The shift from fixed fees to this proportional system mitigates the impact on smaller ports.
Annex II: Fees for Chinese-Built Vessels
Ships constructed in China will face fees calculated either by net tonnage or container capacity (whichever is higher). This provision may increase competitive pressure on Chinese shipbuilders, potentially forcing improvements in vessel quality and operational efficiency.
Annex III: Fees for Non-U.S. Built Vehicle Carriers
The policy imposes fees on vehicle transport ships not built in the United States, presenting challenges for transportation models reliant on imported car carriers.
Annex IV: LNG Carrier Restrictions
Starting in 2028, the U.S. will gradually implement restrictions on liquefied natural gas (LNG) carriers, a strategy expected to gain momentum over the following 22 years.
Market Impact and Industry Response
Facing these impending fees and restrictions, shipping companies are likely to optimize port calls and routes to minimize costs while maintaining competitiveness. Potential strategies include rerouting China-built vessels to non-U.S. trade lanes or reducing port stops to maximize the five-fee cap benefit.
Industry analysts project that major carriers could face approximately $200 per TEU (twenty-foot equivalent unit) under the new policy, with China-operated vessels potentially incurring higher costs. While some less-affected carriers might maintain lower rates to capture market share, others may increase overall pricing to preserve profit margins.
The shipping industry now confronts unprecedented challenges and opportunities as companies' responses to these new fees will significantly influence future market competition dynamics.