China-Linked Vessel Fees: Why Shippers Should Watch for January Vessel Swaps

USTR proposes a two-month extension of China-linked vessel port fee suspensions, but November 9 remains the legal expiration date until finalized. Carriers reshuffled fleets in 2025. Could vessel swaps return ahead of Lunar New Year?

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The U.S. Trade Representative has proposed keeping the Section 301 port fees on China-linked vessels suspended for two more months, through January 9, 2027. The notice published in the Federal Register on October 26 is a proposal open for comment until October 30. Until USTR finalizes the extension, the current suspension still ends at 11:59 p.m. ET on November 9.

The roughly four weeks the fees were active in October and November 2025 offer a useful warning. Several major carriers told customers they would not add a surcharge, while shipping companies redeployed China-built vessels, changed registrations and adjusted services to reduce their exposure. If fees resume on January 10, any further fleet repositioning would coincide with the weeks before Lunar New Year. For cargo owners, the practical risk is a change to the vessel or sailing assigned to a shipment, potentially affecting its ETA and delivery plan even when the original booking reference remains intact.

The published fee schedule, the Annex II exemption list and the contract questions are covered in our August explainer on what returns when the suspension expires. This post covers what the new notice changes and what to watch between now and January.

What the October 26 notice proposes

Current suspensionProposed extension
Window12:01 a.m. ET, Nov 10, 2025 to 11:59 p.m. ET, Nov 9, 202612:00 a.m. ET, Nov 10, 2026 to 11:59 p.m. ET, Jan 9, 2027
Vessel fees coveredAnnexes I, II and IIIAnnexes I, II and III
Equipment duties coveredAnnex V.AAnnex V.A
StatusFinal (Federal Register, Nov 13, 2025)Proposed. Comments close Oct 30, 2026, 5:00 p.m. ET, docket USTR-2026-0694
Section 301 maritime action: current and proposed suspension. Sources: USTR notices in the Federal Register, November 13, 2025 (90 FR 50947), and October 26, 2026 (91 FR 67388).

During the proposed extension, vessel fees would remain suspended under Annex I (Chinese operators and Chinese-owned vessels), Annex II (Chinese-built vessels under other operators) and Annex III (foreign-built vehicle carriers). The Annex V.A duties on ship-to-shore cranes, intermodal chassis and specified chassis parts would remain suspended as well. The applicable exemptions and special rules under each annex would still matter if collection resumes.

Two questions remain. First, the notice does not expressly clarify which fee tier would apply when collection resumes. Under the published calendar-based schedule, the rates for the period beginning April 17, 2026 are $80 per net ton under Annex I and the higher of $23 per net ton or $153 per container discharged under Annex II. Those amounts are the scheduled rates for January 2027, assuming no further modification, but USTR has not separately addressed how the rate increases scheduled during the suspension would be treated on resumption.

Second, the notice is silent on China’s special port fees on U.S.-linked vessels. Beijing suspended those fees for one year from November 10, 2025, in parallel with the U.S. action. Industry expectations reported by Seatrade Maritime suggest Chinese fees could also return if the U.S. fees resume, but a further Chinese suspension would require a separate decision.

November 9 stays the legal date until USTR finalizes the extension

The diplomatic timeline and the fee timeline run on separate instruments. On September 23, Treasury Secretary Scott Bessent said the broader U.S.–China trade truce would be extended to January 10, 2027. That announcement did not itself amend the Section 301 maritime action, which requires a separate USTR modification.

The October 26 proposal signals USTR’s intention to extend the suspension while negotiations continue. It does not guarantee the outcome. Until a final modification takes effect, the November 2025 notice remains the governing instrument, with the current suspension ending November 9, 2026. The comment deadline is October 30 at 5:00 p.m. ET, leaving a relatively short period before the existing suspension expires.

How carriers responded when the fees took effect in 2025

Before the fees started on October 14, 2025, ONE, HMM, CMA CGM and Maersk told customers they would not add surcharges to cover them, according to ICIS. HMM and ONE also said they did not plan to change their U.S. port rotations or existing service plans. Other reported responses involved adjustments to fleets, vessel registrations and individual services:

  • Maersk, MSC and Premier Alliance members were among the carriers repositioning Chinese-built vessels away from U.S. trades, The Loadstar reported. MSC removed the 9,411 TEU MSC Jeongmin from its Mediterranean-to-U.S. West Coast California Express service.
  • CMA CGM said it was implementing fleet and operational adjustments ahead of the October 14 implementation date to maintain U.S. service coverage and reduce fee exposure. Reuters also reported redeployment of Chinese-built vessels.
  • Seaspan, one of the world’s largest containership tonnage providers, relocated its headquarters from Hong Kong to Singapore and reflagged more than 100 vessels, according to Lloyd’s List. These corporate and registration changes illustrate how owners responded to the fee environment, although they do not by themselves establish changes to cargo bookings.
  • Hede Shipping, whose status as a Chinese operator exposed covered U.S. voyages to Annex I fees, discontinued its HDS2 Pacific service.
  • Atlantic Container Line moved a vessel to the U.S. flag, FreightWaves reported.

These examples establish how shipping companies responded to the fees, although they do not measure how many individual shipments were delayed or rebooked. A vessel substitution can leave the original booking reference intact while changing the assigned vessel, voyage or ETA. Depending on when the change occurs, a carrier may issue a revised booking confirmation or require an amendment to shipping documents, including the bill of lading. A cancelled service may require cargo to be rebooked altogether.

For shippers planning U.S.-bound cargo around a possible January restart, the useful question is whether the vessel making the relevant U.S. port call is still the one their delivery plan assumes. That can be particularly important for shipments involving transshipment, where the vessel entering the United States may differ from the one on which cargo began its journey.

If checking vessel substitutions on U.S.-bound bookings means reviewing each carrier’s schedule individually, see how operations teams can monitor vessel and ETA changes across carriers.

Why a January restart could create additional scheduling risk

A January 10 restart would come less than four weeks before Lunar New Year on February 6, 2027. The weeks preceding the holiday commonly bring increased shipping demand as Asian factories prepare for production shutdowns and customers seek to move cargo before the break. Depending on available capacity and individual carrier schedules, another round of vessel repositioning could reduce flexibility for shipments already competing for space.

The concern is greatest where a vessel change also alters the sailing date or available capacity. Cargo rolled from a cancelled or revised sailing may have fewer suitable departures before factories close. But the effect would vary by trade lane and carrier, and a January restart would not automatically produce a system-wide capacity shortage.

The timing of any subsequent decision also matters. The current proposal became available for public inspection on October 23, just 17 days before the existing suspension ends. If another extension is considered near January 9, carriers and cargo owners could again face a short planning window, potentially during the late-December and early-January holiday period. USTR has announced no timetable for such a further decision.

If fees resume under the existing schedule without further modification, the next published rate increase would follow on April 17, 2027. From that date, Annex I specifies $110 per net ton, while Annex II specifies the higher of $28 per net ton or $195 per container discharged, subject to the applicable rules and exemptions. USTR has not clarified whether a resumed action would alter these scheduled increases.

The scale of any second round remains uncertain. Some carriers may already have reorganized their U.S. deployments in response to the 2025 fees, reducing the need for further changes. Others could adjust schedules or vessel assignments again if the charges return. The 2025 responses provide a useful precedent, but they are not a forecast of what individual carriers will do in January.

What to recheck before January

  • Confirm the final notice. Watch the Federal Register after October 30. Verify whether USTR has finalized the extension and whether the new suspension ends on January 9, 2027. Do not treat the proposed date as legally operative until the modification is finalized and effective.
  • Record the vessel on each U.S.-bound leg. For cargo expected to enter U.S. ports from January 10, record the vessel and voyage assigned at booking and recheck them from mid-December. For transshipped cargo, identify the vessel scheduled to make the U.S. port entry. Compare subsequent booking confirmations, sailing schedules and ETA updates against the original plan.
  • Ask how a resumed fee would be billed. Get your carrier’s or forwarder’s position in writing, including any proposed surcharge, its calculation basis and whether the policy differs from October 2025. Confirm which published fee tier the carrier expects to apply, without assuming that a government fee will automatically be passed through to cargo owners.
  • Track China’s fees separately if you ship on U.S.-linked vessels. The U.S. notice does not govern Chinese port charges. Monitor any further announcement from China’s Ministry of Transport. Our explainer on China’s retaliatory port fees covers the vessel categories involved.
  • Check contracts that run past January 9. Review change-in-law provisions, surcharge definitions and vessel-substitution clauses. The contract questions in the August explainer remain relevant even if the suspension is extended. The applicable terms will depend on the specific contract and the final regulatory action.

Further Reading

Suspension windows, annex coverage and comment deadlines are taken from the USTR notices published in the Federal Register on November 13, 2025 (90 FR 50947) and October 26, 2026 (91 FR 67388). The October 2026 notice is a proposal and had not been finalized at publication. Fee amounts for April 2026 and April 2027 are from the published USTR schedule of April 23, 2025 (90 FR 17114). The proposal does not expressly clarify the treatment of scheduled fee increases on resumption. Carrier responses in 2025 are drawn from contemporary reporting by ICIS, The Loadstar, Reuters, Lloyd’s List and FreightWaves, alongside carrier statements; these historical actions may not reflect current or future vessel deployments. Operational examples describe potential consequences and should not be read as evidence that every vessel substitution affected a booking or shipment. Confirm current regulatory status with USTR or CBP and applicable charges with the carrier and relevant contract before acting. Status as of October 26, 2026.

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