Chinese Ship-Fee Restart Would Widen the Cost Gap Between Carriers
A Chinese ship-fee restart on the existing schedule would widen the cost gap between vessels with Chinese owners or operators and other Chinese-built ships.
Primary lensTrade policy
Sub-topicPolicy monitoring
Evidence base4 records used
Use casePolicy monitoring
A restart of Chinese ship fees under the published schedule would widen the cost gap between vessels covered by Chinese ownership or operation and other qualifying Chinese-built ships. Two ships from the same Chinese yard could face sharply different charges. For a U.S. importer comparing ocean services, the next suspension decision therefore affects which existing fleet offers lower fee exposure, as well as when collection could resume.
The distinction matters to that investment debate. A carrier may be able to offer a lower-fee vessel already in service. That could lower the government-fee exposure behind the service without itself producing an order for an American-built replacement.
The suspension paused collection without rewriting the rate dates
That notice does not replace the April 17 escalation dates in the underlying fee schedules. An unchanged restart would therefore require a comparison using the dated 2026 rates, rather than simply restoring the 2025 starting rates. Those scheduled rates are a planning assumption, not an announcement that collection will resume.
The April 2025 maritime Section 301 action, 90 FR 17114, Annexes I and II, separates ownership and operation from construction. Annex I reaches covered Chinese owners or operators regardless of the vessel's build country. Annex II applies to qualifying Chinese-built vessels after the higher-priority categories have been ruled out. The fees do not stack.
The Annex I definitions reach specified ownership and control links, including parent-company connections. A fleet's advertised nationality or share of Chinese-built ships does not settle that test. Hiring a non-Chinese operator would not put a vessel under Annex II if its owner still triggers Annex I.
The same shipyard can produce different fee exposure
Consider two hypothetical container ships, each built in China, with 60,000 net tons, capacity above 4,000 TEU and 6,000 containers discharged. Assume both make a chargeable U.S. arrival, neither qualifies for an exemption or remission, and neither has reached the annual assessment limit. One has an owner or operator that triggers Annex I. The other's owner and operator do not, leaving it under Annex II.
Annex II uses the higher of its tonnage calculation and its container calculation. In this example, the tonnage calculation is higher in all three years. The figures below compare one assessment on each vessel. They are not freight quotes or charges owed by cargo customers.
Published fee tier
Annex I vessel
Annex II vessel
Difference
October 14, 2025
$3.00 million
$1.08 million
$1.92 million
April 17, 2026
$4.80 million
$1.38 million
$3.42 million
April 17, 2027
$6.60 million
$1.68 million
$4.92 million
The calculation applies the Annex I and II schedules. The 2026 row uses $80 per net ton under Annex I. Under Annex II, $23 per net ton produces $1.38 million, above the $918,000 produced by 6,000 containers at $153 each. The 2027 comparison uses $110 and $28 per net ton, respectively. Its $195-per-container calculation also remains below the tonnage amount.
Nothing about the assumed shipyard, tonnage or cargo changes across those rows. The growing difference comes from the two schedules. A buyer comparing only Chinese-built against non-Chinese-built capacity would miss it.
A lower vessel charge does not require an American replacement
The widening gap gives procurement a reason to examine existing alternatives. A service using a qualifying Annex II ship could carry less government-fee exposure than one using an otherwise comparable Annex I ship, even though both vessels came from Chinese yards. The fee structure can therefore reward a change in the fleet serving the route before it rewards a change in shipbuilding location.
That is an inference about the incentive created by the rule. It does not establish that suitable alternative space is available, that carriers will redeploy particular ships, or that they will pass through the difference to customers. Route coverage, transit time and reliable capacity can outweigh a lower vessel-level fee. An importer should not discard a workable service on the strength of the table alone.
Annex II also provides a direct incentive for American construction. Its U.S.-built vessel remission provision permits conditional relief tied to an order and delivery of a qualifying U.S.-built replacement within three years. That route requires evidence of a qualifying U.S.-built vessel order, unlike selecting a lower-fee ship already in service. The narrower conclusion is that a reduction in one buyer's carrier exposure would not itself demonstrate a new U.S. order. The two outcomes need different evidence.
For the coalition's argument, that distinction matters. Extending the pause would avoid near-term collection under the present action. Evaluating a restart as an industrial policy would also require evidence about orders, delivery capacity and investment, beyond the amount charged on an existing vessel.
Compare the nominated vessels before choosing the service
The immediate procurement task is to put the competing services on the same assumptions. Ask each carrier to identify the vessel expected to serve the relevant sailing and the owner and operator used for its U.S. entrance record. Review the applicable annex, relevant control relationships, tonnage, expected discharge and any claimed exemption. The October USTR clarification applies the 4,000-TEU size threshold to fully cellular container ships and measures short-sea voyages from the furthest foreign port call. Annex II exclusions cannot simply be carried into Annex I. A different vessel nomination can change the comparison even if the carrier's quoted base rate remains the same.
Use the same conditional collection date and published rate tier for both services. Keep an extension case alongside the unchanged-restart case, and identify the point at which higher government-fee exposure would change the service choice. This produces a decision that can be revised when USTR acts, without pretending to know the outcome of the talks.
Traverse's RoRo fee and freight-surcharge analysis addresses the separate question of allocating vessel charges through freight surcharges. Compare the next USTR notice with the April maritime action in Traverse Policy Signals. If an extension changes only its endpoint, an eventual restart after April 17, 2027 would encounter another scheduled increase. A notice that also revises the rates or coverage would require a different vessel comparison. Those provisions, alongside actual carrier quotations and available space, should determine the service choice.
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