USTR RoRo Port Fees Make 2027 Auto Freight Quotes Harder to Compare
USTR's paused Section 301 RoRo fees depend on each ship's net tonnage and annual charge count, making 2026/27 auto freight surcharges a contract question.
Primary lensTariff authority
Sub-topicSection 301 track
Evidence base6 records used
Use caseAuthority exposure review
For an automotive logistics manager negotiating freight into 2027, the USTR port-fee pause creates a pricing decision now. A quote can reserve the right to charge for a future government fee while saying little about which vessel will incur it, how often, or how the cost will be divided among customers. Those omissions matter because the underlying charge follows the vessel and calendar year.
As of September 2, 2026, the maritime Section 301 fees remain suspended. USTR's November 2025 suspension notice bars new fee liability during the suspension through November 9, 2026. USTR may extend the pause or take further action before the deadline. Procurement teams should therefore price a conditional resumption and write down how the quote changes if the policy does.
The fee starts with the ship
If collection resumes unchanged, the October modification of Annex III requires a covered foreign-built vehicle carrier to pay $46 per net ton at its first U.S. entry from outside the customs territory on a string of port calls. Collection is limited to five times per calendar year, per vessel. Several U.S. stops on that string do not each generate another Annex III fee.
That structure supplies no government-set price per imported car. Net tonnage is also a different measure from gross tonnage, deadweight or the number of cars aboard. The International Maritime Organization's tonnage convention overview explains that gross and net tonnage concern vessel volume, rather than cargo weight. A fleet brochure listing gross tons and car capacity is insufficient for this calculation.
The practical consequence is that a cargo forecast alone cannot establish the carrier's fee exposure. Procurement needs the nominated vessel's relevant tonnage and anticipated chargeable strings. Allocating that expense to cars, customers or a wider service is a separate pricing decision. A carrier can propose such an allocation, but the quote should identify it.
January opens a new annual count
The suspension deadline and annual cap run on different clocks. If the existing fees resume on November 10, a covered entry later that year falls into the 2026 count. January 1 begins a new count. A contract extending across both years cannot treat its entire term as one five-charge allowance.
Consider a hypothetical Annex III vessel of 30,000 net tons, with no applicable exemption or remission. Assume one chargeable string after November 9, 2026, and six during 2027. Each uncapped charge would be $1.38 million. These are assumed schedules and carrier fees, not freight-market estimates or amounts owed by an individual customer.
Assumed period
Covered strings
Fee collections
Carrier fee total
November 10 through December 31, 2026
1
1
$1.38 million
Calendar year 2027
6
5
$6.90 million
Combined
7
6
$8.28 million
The calculation applies the current $46 rate and annual cap, assuming both remain unchanged. The sixth 2027 string produces no additional Annex III charge in this example. It does not follow that every customer on that sailing must receive a surcharge-free rate. A contract could distribute earlier expenses across later shipments. The buyer needs that method disclosed before comparing bids.
Check coverage before comparing vessel costs
An alternative vessel is useful only after its applicable fee category is established. The April Section 301 action makes the Annex I, II and III fees noncumulative. A spreadsheet that adds all three overstates liability. One that assumes every foreign-built vehicle carrier can claim the exemptions for Chinese-built vessels under Annex II can understate it.
The October notice placed its empty-or-ballast clarification under Annex II. It did not create a general empty-ship exemption for Annex III. The adopted Annex III exclusions cover U.S.-owned or U.S.-flagged vessels enrolled in the Maritime Security Program and defined U.S. Government vessels. The program exclusion expires April 18, 2029, unless renewed. The notice's separate proposal for U.S.-flag vessels up to 10,000 deadweight tons should not be treated as an adopted exclusion on the strength of that notice.
A claimed U.S.-newbuild remission also requires evidence. Annex III permits conditional relief for a qualifying U.S.-built replacement with equal or greater car-carrying capacity, beginning with the order and requiring delivery within three years. Failure to take timely delivery makes the fees due. For bid comparison, record the precise basis claimed and request supporting documents instead of treating an order announcement as a permanent exemption.
Match the surcharge to an assessable voyage
CBP's implementation update puts responsibility for determining and paying the fee on the vessel operator. Its payment process identifies the vessel, IMO or official number, voyage, arrival port and date, operator and applicable Annex. Pay.gov sends confirmation to the Vessel Entrance and Clearance System.
Those records offer a basis for checking an actual-cost surcharge. The buyer's reconciliation sheet should connect the billed shipment to the vessel and chargeable string, then record assessed fees and the annual count. A separate column should show the agreed allocation, including the cargo sharing the expense, the quantity used to divide it and the customer's resulting share. This is a proposed procurement control, not a CBP requirement imposed on cargo owners.
Traverse's analysis of IEEPA surcharge evidence addressed a different refund dispute. The customer invoice and the government payment remain distinct pieces of evidence in this setting too. Neither document alone explains the commercial allocation between them.
Agree the adjustment before the next notice
The contract should distinguish an actual-cost reimbursement from a fixed surcharge or an allocation of fleet-wide costs. For an actual-cost provision, agree what documentation will support the amount, when estimates will be reconciled and how credits will be handled. For a fixed charge, identify the conditions under which it starts, changes or ends. A reference to "USTR fees" leaves those questions unanswered.
The next official decision must be compared with the October USTR modification recorded in Traverse's Policy Signals, alongside the suspension notice. An extension changes the collection window. A modified rate, cap or exclusion changes the vessel calculation. A different nominated vessel changes the commercial assumptions even if the law stays the same.
Before accepting a 2026/27 quote, have the carrier attach its nominated vessels, assumed chargeable strings and allocation method to the fee clause. Those assumptions are what procurement will need to test when the first invoice arrives.
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