This post skips the background and goes straight to a vessel screening you can run before cutoff, plus what to log on quotes and invoices.
The 5-point vessel test
If any single item is true for the ship on your booking when it berths in China, the special port fee applies.
- Owner is U.S. company, organization, or individual.
- Operator is U.S. company, organization, or individual.
- ≥ 25 percent U.S. ownership or control in the owning or operating entity (equity, voting rights, or board seats).
- U.S. flag.
- U.S. build.
Scope and charging rule: the fee is per voyage and collected at the first Chinese port only, capped at five chargeable voyages per vessel in one year. Rate schedule: RMB 400 per net ton from Oct 14, 2025, then RMB 640 on Apr 17, 2026, RMB 880 on Apr 17, 2027, RMB 1,120 on Apr 17, 2028.
Concrete cases you can recognize
- Obvious in scope: U.S. operator with China calls. Example used by many readers: Matson CLX and MAX strings call Ningbo and Shanghai. Operator is U.S., so the vessel meets the operator trigger on those China calls.
- Sometimes in scope: a time-chartered ship on a non U.S. liner where the registered owner or commercial operator has ≥ 25 percent U.S. equity or control. This is vessel by vessel and needs a quick ownership check.
- Usually out of scope: a non U.S. liner using a non U.S. flag, non U.S. build ship where neither owner nor operator meets the 25 percent U.S. threshold. Still verify the actual ship that is assigned to your booking.
What to do at each stage
Before booking
- Add a vessel field set to pre-advice: flag, build country, registered owner, commercial operator, and any public note on equity or board control.
- Run the 5-point test. If any trigger hits, tag as “China special port fee likely” and brief the customer.
At cutoff
- Confirm first-port rule in writing with the carrier’s China agent if the rotation includes multiple China ports. Save the reply in the shipment record.
- If the carrier swaps the vessel, run the test again. A swap can move you into or out of scope.
After arrival
- Invoice audit: the fee is based on Net Tonnage from the vessel’s certificate. Reconcile the RMB line against NT and the phase rate for that date.
- Cap tracking: count how many chargeable voyages the ship has this year. After five, additional calls in the same year should not be charged. Ask the local agent to confirm the count when it is close.
Minimal FAQ for your ops playbook
Is it per port or per voyage
Per voyage. Collected at the first Chinese port only when a voyage calls more than one China port.
Is there a limit per vessel
Yes. No more than five chargeable voyages per ship in one year.
Can I quote a per-container number
Avoid that unless the carrier publishes an allocation method. The rule is per net ton at the vessel level.

Track status, exceptions, and ETAs in one place with TRADLINX Container Tracking
References
- China Ministry of Transport — official announcement in Chinese
- AP News — China to charge special port fees on U.S. linked ships
- Reuters — timing and staged rate schedule
- SP Global Commodity Insights — fee triggers and mechanics
- Matson — China services overview
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Prefer email? Contact us directly at min.so@tradlinx.com (Americas) or henry.jo@tradlinx.com (EMEA/Asia)





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