Section 301 Investigation: China's Shipbuilding, Maritime & Logistics Sectors

New! On November 9, 2025, USTR announced the suspension of all actions for one year as of 12:01 am Eastern Standard Time on November 10, 2025. None of the below measures are currently in effect.

ST&R offers a three-pronged approach to avoiding, mitigating, and/or recovering tariffs on imported goods. For more information on the impact of the new tariffs, and which of these strategies might be most effective for your business, please contact ST&R.

Previously Implemented Measures

April 2025 Initial Measures

The below measures were in place from April 23, 2025 - October 10, 2025.

Fees

Chinese-owned or -operated vessels

Any vessel with a Chinese operator or owned by an entity of China (except liquefied natural gas carriers and vehicle carriers; see below) will be assessed a fee on or before entry into a U.S. port.

Effective date	Fee/net ton
Oct. 14, 2025	$50
April 17, 2026	$80
April 17, 2027	$110
April 17, 2028	$140

Given the potential impacts to small ports if this fee were to be assessed at each port of call, the fee will be assessed (1) upon entry at the first U.S. port or place from a foreign destination per rotation or string of U.S. port calls, (2) at the first U.S. port within the U.S. customs territory, and (3) no more than five times a year on an individual vessel.

Chinese-built vessels

Non-Chinese operators of Chinese-built vessels will pay the higher of the per ton or per container fees set forth below upon the arrival of such vessels into a U.S. port.

Effective date	Fee/net ton
Oct. 14, 2025	$18
April 17, 2026	$23
April 17, 2027	$28
April 17, 2028	$33

Effective date	Fee/container discharged
Oct. 14, 2025	$120
April 17, 2026	$153
April 17, 2027	$195
April 17, 2028	$250

This fee will also be assessed (1) upon entry at the first U.S. port or place from a foreign destination per rotation or string of U.S. port calls, (2) at the first U.S. port within the U.S. customs territory, and (3) no more than five times a year on an individual vessel.

However, the fee may be suspended for a particular vessel for up to three years if the vessel owner orders and takes delivery of a U.S.-built vessel of equivalent or greater tonnage within that period. In addition, there are a number of exemptions from this fee, including for vessels below certain size or capacity thresholds, vessels engaged in short sea shipping, and certain U.S.-owned companies’ vessels.

LNG carriers

From April 17, 2028, to April 16, 2029, one percent of liquefied natural gas intended for exportation by vessel in a calendar year must be exported on U.S.-flagged and -operated vessels.

Beginning April 17, 2029, one percent of LNG exports must be exported by U.S.-built, -flagged, and operated vessels, and that amount will increase incrementally to 15 percent as of April 17, 2047.

These restrictions will not apply to a particular vessel for up to three years if the vessel owner orders and takes delivery of a U.S.-built LNG vessel of equivalent or greater capacity within that time.

Tariffs

USTR accepted public comments through May 19, 2025 on a proposal to impose additional tariffs (i.e., in addition to all other applicable duties, taxes, and fees already in place) on (1) ship-to-shore cranes manufactured, assembled, or made using components of Chinese origin, or manufactured anywhere in the world by a company owned, controlled, or substantially influenced by a Chinese national, and (2) certain cargo handling equipment of China.

Item	HTSUS	Proposed tariff rate
Containers	8609.00.00	20-100 percent
Chassis	8716.39.0090	20-100 percent
Chassis parts	8716.90.30	20-100 percent
Chassis parts	8716.90.50	20-100 percent
Ship-to-shore gantry cranes	8426.19.00	100 percent

Other

Readers are reminded that additional fees and/or other restrictions on inbound ships are still possible as a result of an ongoing investigation by the Federal Maritime Commission as well as the federal agency actions directed by an April 9 executive order.

October 2025 Changes

On October 10, 2025, USTR announced several actual and proposed changes to these new fees. The modifications being made include:

changing the basis for calculating service fees on vessel operators of foreign-built vehicle carriers and setting the fee at $46 per net ton, effective Oct. 14
eliminating, retroactive to April 17, 2025 a provision permitting the suspension of liquid natural gas export licenses if certain restrictions on the use of foreign-built vessels are not met, and
imposing tariffs of 100 percent on imports of certain ship-to-shore cranes and cargo handling equipment, effective Nov. 9, 2025.

Beginning Oct. 14, 2025, foreign-built vehicle carrier vessels will be required to pay $46 per net ton on or before entry into a U.S. port. This rate was changed in an October 10 notice from the previous rate of $150 per car equivalent unit capacity. This fee may be suspended for a particular vessel for up to three years if the vessel owner orders and takes delivery of a U.S.-built vessel of equivalent or greater CEU within that period.