The maritime logistics landscape is about to shift significantly. Beginning October 14, 2025, the US Trade Representative will implement a new port fee structure targeting Chinese-owned, Chinese-operated, and Chinese-built vessels entering US ports. The phased approach, plateauing in 2028, represents the most substantial change to US port cost structures in decades.
The Fee Structure
The fees are structured across four non-cumulative annexes, with only one applicable per vessel rotation based on priority order:
Annex I – Chinese Vessel Operators and Owners
Starting at $50 per net ton on October 14, 2025, and increasing to $140 per net ton by April 2028. For context, a typical 13,000 TEU container vessel with 65,000 net tons would face a $3.25 million fee per rotation at current rates – roughly $250 per TEU when fully loaded. By 2028, that same vessel would incur $9.1 million per rotation.
Annex II – Chinese-Built Vessels
The higher of $18 per net ton or $120 per container, rising to $33 per net ton or $250 per container by 2028. Critically, these fees apply per rotation (a string of US port calls), not per individual port entry, with a maximum of five rotations charged per vessel annually.
Annex III – Foreign-Built Vehicle Carriers
$150 per Car Equivalent Unit (CEU) for non-US-built vehicle carriers.
Annex IV – LNG Vessels
Separate requirements for liquefied natural gas transport.
The Context Behind the Policy
The fees stem from a Section 301 investigation initiated in April 2024, which concluded that China’s acts, policies and practices in the maritime sector were “unreasonable and burden or restrict U.S. commerce”. The stated objectives are straightforward: reverse Chinese dominance in shipping, address US supply chain vulnerabilities, and create demand signals for US-built vessels.
The policy evolution is salient here. The original February 2025 proposal called for fees up to $1 million per port call for Chinese-operated vessels and $1.5 million for Chinese-built vessels. Following public comments from over 300 trade groups during March hearings, the USTR pivoted to the tonnage-based and container-based structure now being implemented – a recognition that the original approach would have been economically untenable.
Industry Response
The shipping industry isn’t waiting for October to react. Israeli carrier Zim, which operates “a bit less than half” Chinese-built tonnage according to CFO Xavier Destriau, is already working to shift vessel deployment between trades to minimize exposure. Okeanis Eco Tankers moved proactively, exercising purchase options on three VLCCs to acquire them from Chinese sale-and-leaseback financiers, then refinancing through a Greek bank.
The Ocean Alliance faces particularly complex optimization challenges. COSCO, a major alliance member and Chinese operator, will be heavily impacted by Annex I. The alliance’s typical strategy of deploying CMA CGM and Evergreen vessels to US routes while using COSCO and OOCL ships elsewhere becomes more complex when considering that CMA CGM has over 35% of its orderbook at China State Shipbuilding Corporation yards.
Contractual Implications
The fees create significant contractual uncertainty. Under typical English law time-charter agreements, charterers bear responsibility for port-related costs. BIMCO has issued a standard clause requiring owners to disclose vessel information and assigning financial responsibility for USTR fees by default to charterers. However, if fees render charters economically burdensome, questions arise about relief under “onerous” or “frustrated” contract clauses.
The five-rotation annual cap introduces another complexity. Carriers making more than five US rotations yearly cannot recover costs through the fee structure alone – they’ll likely spread costs across all sailings, potentially passing surcharges to customers through freight rates or accessorial charges regardless of whether specific sailings incur fees.
The Bigger Picture
Chinese shipyards captured 53% of all global ship orders by tonnage during the first eight months of 2025, according to Center for Strategic and International Studies analysis of S&P Global data. The USTR fees are one element in a broader policy framework that includes proposed tariffs on Chinese-built containers, chassis, and ship-to-shore cranes, plus the reintroduced SHIPS for America Act with its phased requirements for US-flagged vessel cargo preference.
These policies reflect a calculated bet: that sustained financial pressure will shift global orderbook composition away from Chinese yards toward South Korean, Japanese, and eventually American shipbuilders. Whether this achieves the stated objectives or simply increases costs across supply chains will become clear over the next several years.
What This Means for Shippers and Importers
For organizations shipping to the US, several considerations emerge:
The fees will affect ocean freight costs, though the per-container impact varies significantly based on vessel utilization and routing. A fully loaded 13,000 TEU vessel faces roughly $250 per TEU in fees at current rates – material but not prohibitive given typical container cargo values.
More significant is the strategic uncertainty. Carriers are actively restructuring routes and fleet deployment. Service patterns that worked in 2024 may look substantially different by Q4 2025. Supply chain teams should be engaging carriers now about potential service changes, understanding which vessels serve specific routes, and reviewing contract pass-through clauses.
Logistics experts increasingly recommend index-linked contracts as one approach to manage this volatility – allowing procurement teams to focus on operational delivery rather than constantly renegotiating rates amid market disruptions.
Looking Forward
The October 14 implementation date is firm barring legal challenge or administrative delay. US Customs and Border Protection will enforce the fees, with detailed implementation guidance expected in the coming months. Several technical questions remain unanswered – including whether the five-rotation annual cap applies per calendar year or rolling twelve-month period.
What’s clear is that the maritime logistics environment of late 2025 and beyond will look fundamentally different from what preceded it. Organizations with significant US import exposure should be modeling scenarios now, understanding their carrier exposure to the new fee structure, and building flexibility into their supply chain strategies.
The port fees represent more than just increased costs – they’re a signal of shifting trade policy priorities and growing recognition of maritime logistics as a strategic consideration rather than purely an operational one.
Need help navigating these changes in your supply chain? Our team at tva stays current on global logistics developments and their practical implications. Get in touch to discuss how these policy shifts might affect your operations.