Understanding the US section 301 maritime service fees
Date of Publication: May 16, 2025
Background
On April 23, 2025, the USTR took targeted action to restore American shipbuilding and address China’s unreasonable acts, policies, and practices to dominate the maritime, logistics, and shipbuilding sectors.
In March 2024, a Section 301 petition was entered by five national labor unions requesting an investigation into the acts, policies, and practices of China targeting the maritime, logistics, and shipbuilding sectors for dominance. An official investigation was initiated on April 17, 2024. On January 23, 2025 the USTR issued a Federal Register Notice (FRN) that China's targeting of the maritime, logistics, and shipbuilding sectors for dominance is actionable under section 301. Subsequently, on February 21, 2025, USTR issued a FRN proposing certain responsive action, including service fees and restrictions on certain maritime transport services – this was followed by a comment period and public hearings, whereby the USTR received nearly 600 public comments and consulted with government agency experts and USTR cleared advisors. On April 9, 2025, the President issued Executive Order 14269, “Restoring America's Maritime Dominance” recommending specific actions. The corresponding FRN was published April 23, 2025.
Regulators will issue more implementation details for the actions in the next few months. USTR is also proposing to impose additional tariffs on certain ship-to-shore cranes, shipping containers, truck chassis and chassis parts.
Summary of changes
As a result of the review of public comments and testimony at the hearings and taking into consideration the advice of advisory committees and the agencies which regulate the services involved, the following actions were deemed appropriate.
The actions introduce new fees on ocean vessels as a countermeasure to certain Chinese policies. The overall goal is to put pressure on China and bolster the U.S. maritime and shipbuilding industry. These new fees specifically target three categories of shipping operations.
Effective October 14, 2025, Section 301 maritime fees introduce new cost schedules for these categories of vessels tied to China:
- Annex Iapplies to Chinese-operated ships at $50 / net ton (NT) in 2025, increasing to $140 / NT by April 17, 2028
- Annex IIcovers any Chinese-built ship (regardless of operator) at the higher of $18 / NT or $120 per container in 2025, climbing to $33 / NT or $250 per container by 2028.
- Annex IIIapplies a service fee on all foreign-built vehicle carriers, regardless of the country of construction or owner/operator (unless the ship is built in the US). The fee is based on the Car Equivalent Unit (CEU) capacity of the ship, set at $150 per CEU capacity of the entering foreign-built vessel beginning on October 14, 2025. Chinese-operated, Chinese-owned, and Chinese-built vehicle carriers would not be covered by the China-specific fees. This fee does not increase each year.
- Each vessel will be charged up to five times annually, once per U.S. rotation, meaning exposure depends on frequency of service and composition of the fleet.
Under the Section 301 action, any given vessel entering U.S. ports will be subject to either Annex I, Annex II or Annex III fees (or none), depending on its ownership and build (these are not cumulative). In other words, a ship operated by a Chinese entity triggers Annex I (even if it’s Chinese-built), while a non-Chinese-operated ship that was built in China triggers Annex II (unless an exemption applies). Only one fee applies per voyage, assessed on the vessel’s first U.S. port of call in a given trip (covering all subsequent stops on that route). The fee is charged at most once per rotation (string of U.S. port calls) to prevent double-charging a single voyage.
Liquified natural gas (LNG) tankers, which are exempt from the service fees, will instead face a rule requiring an increasing percentage of US LNG exports to be carried on US-built LNG tankers. The restrictions will enter effect in 2028.
Exemples of potential cost impact
Scenario 1: Chinese-Operated Vessel (Annex I)
Large container vessel (Chinese-operated) calling at U.S. ports on the west coast
Vessel: 14,000 TEU capacity (e.g. ~80,000 NT net tonnage).
Cargo Volume: On each U.S. call, it carries ~7,000 containers for U.S. importers.
U.S. Calls: 6 full rotations per year (roughly on US call every two months based on roundtrip transit time from Asia). Under Annex I, only 5 of those incur fees due to the cap of five per year; one voyage would effectively be free of the fee.
Initial impact (late 2025): At the $50/NT rate, each call costs $50 × 80,000 = $4 million in fees. With ~7,000 containers, that works out to $571 per container in added cost. If the ship calls 5X in a year with the fee, that’s $20 million annually in new fees for that one vessel. Those costs will be spread across all importers using that ship (likely as a surcharge). For an importer moving 100 containers on that voyage, that’s roughly an extra $57,000 on that shipment’s cost.
Full impact (by 2028): At $140/NT, each call would incur $140 × 80,000 = $11.2 million in fees – roughly $1,600 per container if 7,000 boxes are aboard. Five such voyages in a year would tally $56 million in fees on this one ship. Even if carriers optimize loading, the per-container fee equivalent is on the order of hundreds to over a thousand dollars. In practice, a carrier might try to maximize utilization to dilute the fee per box (or conversely might deploy a smaller ship – but that has its own capacity trade-offs). Either way, importers using a Chinese carrier could see somewhere from $500 to $1,500+ added per container by the late stages of this policy, depending on vessel size and load factor.
Example provided by Bluspark, LLC.
Scenario 2: Non-Chinese Carrier with Chinese-Built Ship (Annex II)
Global carrier (not Chinese-owned) – for instance, a European shipping line – that happens to use some vessels built in China
Vessel: 10,000 TEU capacity (~ 60,000 NT). The ship was built at a Chinese shipyard, so Annex II applies.
U.S. Calls: 4 rotations per year (quarterly service). All would be subject to the fee (within the 5/year cap). Cargo Volume: ~5,000 containers delivered to U.S. per voyage (typical for a 10k TEU ship, assuming many 40′ containers).
Late 2025: At initial rates $18/NT vs $120/container, the higher fee would likely be the tonnage-based: $18 × 60,000 = $1.08 million per voyage, versus $120 × 5,000 = $600,000. So, the ship pays $1.08M (tonnage method). That’s roughly $216 per container in this scenario. For four voyages, total yearly fees = ~$4.3M.
By 2028: Rates $33/NT vs $250/cont. Now tonnage fee = $33 × 60,000 = $1.98 million; container fee = $250 × 5,000 = $1.25 million. Here the tonnage fee is still higher, so the ship pays ~$1.98M (about $396 per container). If the ship had more cargo (say 6,500 containers), if 8,000 containers, container fee $2M beats tonnage $1.98M). In any case, we’re looking at on the order of $250–$400+ per container in added cost by 2028. Four voyages would rack up ~$7.9M annually in fees for this vessel.
Example provided by Bluspark, LLC.
The fees themselves will be charged to the ocean carriers. However, carriers have publicly stated their intent to pass these fees through to importers. As a result, total landed costs for imports will rise as these fees are implemented. Importers will face higher ocean freight bills, which translate into higher costs per unit of goods imported.
Other maritime actions of concern
In the same notice, USTR issued a new proposed action to impose an additional 100% tariff on ship-to-shore cranes built by China-linked entities or that incorporate China-origin components (regardless of the country in which the crane was manufactured), as well as additional tariffs of 20% to 100% on China-origin shipping containers, truck chassis and chassis parts. The timeline for completing and implementing the tariffs is yet to be determined, and USTR is seeking public input on the proposal. Comments are due May 19, 2025. Interested stakeholders may submit comments using docket number USTR–2025–0008 on USTR's docket at comments.ustr.gov. Companies should also take note of President Trump's April 9 Executive Order (EO) on "Restoring America's Maritime Dominance" establishing the Maritime Action Plan and recognizing the USTR's proposed vessel restrictions. It also proposed a number of additional actions that would impact foreign shipping. The EO instructs the Department of Homeland Security (DHS) to "take all necessary steps, including proposing new legislation, as permitted by law" to:
- "require all foreign-origin cargo arriving by vessel to clear the Customs and Border Protection (CBP) entry process at a United States port of entry for security and collection of all applicable duties, customs, taxes, fees, interest and other charges;" and
- "ensure any foreign-origin cargo first arriving by vessel to North America clearing the CBP process at an inland location from the country of land transit (Canada or Mexico) is assessed applicable customs, duties, taxes, fees (including the HMF [Harbor Maintenance Fee]), interest and other charges plus a ten percent service fee for additional costs to the CBP, so long as the cargo being shipped into the United States is not substantially transformed from its condition at the time of arrival into the country of land transit (with the discretion for such decisions to be determined by CBP)."
The land border fee proposal is likely based on concerns that vessel operators will attempt to bypass the new vessel fees by unloading cargo in Canada and Mexico instead of the United States. Following the issuance of President Trump's April 9 EO and USTR's final Section 301 notice, Congress reintroduced a bill that would make permanent measures like those proposed by President Trump and implement measures that would require new law. The bipartisan bill, the "SHIPS for America Act of 2025," was introduced April 30, 2025. This bill incorporates the USTR’s Section 301 fees.
Conclusion
With the reality of these new fees coming into effect later this year, Importers will need to take proactive steps to consider how to manage increasing supply chain costs. Direct communication with supply chain and logistics teams will be critical to determine the best strategy to mitigate the potential cost impacts. This could include understanding which trade lanes are using carriers subject to the new fees, possible renegotiation of carrier contracts (make sure to include discussion of Section 301 fees), explore alternate carrier options (e.g., US flag), or front load imports prior to fees kicking in. To learn more about how the ONESOURCE Global Trade suite of tools and services can help businesses analyze potential impacts, explore alternative sourcing options, and optimize their trade operations to mitigate risks and capitalize on potential advantages, please contact your Account Manager or Customer Success Manager.