Expert Column Impact and Outlook of U.S. Trade Representative (USTR) Port Entry Fee

1. USTR Port Entry Fee Imposition

The U.S. Trade Representative (USTR, Office of the United States Trade Representative) announced a policy in February 2025 to impose port entry fees on Chinese-flagged/operated vessels. This measure was announced after the USTR initiated a Section 301 investigation under the Trade Act in April 2024, following a petition filed in March 2024 by five labor unions, including the United Steelworkers (USW), requesting an investigation into unfair practices in China's shipping, logistics, and shipbuilding industries. The investigation report concluded that China had engaged in unfair practices and undue policy support to dominate the global shipping and shipbuilding industries. The USTR's measure aligns with the policy objectives of the executive order aimed at "Restoring America's Maritime Dominance." Ultimately, the goal is to restore the competitiveness of the U.S. shipbuilding industry and reduce the vulnerabilities in supply chains that emerged during the COVID-19 pandemic.

The fees announced by the USTR consist of four main items.

First, it is imposed on vessels owned or operated by Chinese companies. The fee is based on the net tonnage (NRT, Net Register Tonnage), and the rate starts at $50 per net ton at the time of enforcement on October 14, 2025, which will be incrementally increased to $140 by 2028. However, the number of times the fee is levied is limited to a maximum of five times per individual vessel annually.

Second, it applies to vessels built in China but not necessarily owned or operated by China; it is characterized by a dual-rate structure where you get to choose the higher amount from two calculation methods. The fee is imposed based on the higher amount between the rate per net ton ($18 per net ton) and the rate that charges $120 per container transported. The fee will also be gradually increased until 2028; however, coastal vessels operating within 2,000 nautical miles and vessels below a certain scale (4,000 TEU container ships, 55,000 DWT bulk carriers) are exempted from the fee.

Third, regulations regarding specialized vessels (automobiles/LNG carriers) were also added, with the imposition of $46 per net ton for automobile carriers confirmed. In addition, a proposal was made for a mandatory ratio of U.S.-flagged vessels for LNG transport, but this was removed from the final plan.

The USTR regulations, which have been in effect since October 14, were less strict than the regulatory proposal released in February, but the scope of vessel types was expanded. In the first proposal, the regulations targeted Chinese carriers, carriers operating Chinese-flagged vessels, and carriers that ordered vessels from Chinese shipyards. However, the scope was later expanded to include all automobile carriers except for non-U.S.-built carriers. However, while the February announcement estimated that an 8,000 TEU container ship entering a U.S. port would incur costs of $2.5 to $4.5 million, the April announcement lowered this to 30~35% of the February proposal. Moreover, to prevent evasion of the exemption clauses for vessels operating within 2,000 nautical miles, the criteria were changed to the farther location based on the origin.

2. Impact on the Shipping Market

As of 2024, it is estimated that the proportion of Chinese-built vessels entering U.S. ports is around 30%, with the highest share being general cargo ships. However, most general cargo ships and tanker ships are exempt from the USTR port entry fees, and the market expected to be most affected by this USTR measure in the shipping sector is containers. In the case of containers, the fees will be imposed on vessels operated by Chinese shipping companies and those built in China, which is expected to significantly burden shipping companies with a high proportion of such vessels. As of September 2025, a total of 170 vessels from the top 10 container shipping companies are subject to USTR's entry fees. Among these, the Chinese company COSCO has the highest number of vessels subject to fees, while ZIM Integrated Shipping Services and MSC (Mediterranean Shipping Company S.A.) have a large number of Chinese-built vessels.

<Number of Vessels Owned Subject to USTR Port Entry Fees>
(Unit: Number of vessels) As of September 2025
Source : Alphaliner (2025), Edited by Author

As of 2026, the estimated amount of port entry fees to be levied in the U.S. amounts to approximately $1.53 billion for COSCO followed by ZIM Integrated Shipping Services ($510 million), and ONE ($360 million). Furthermore, top 10 container shipping companies are expected to pay about $3.24 billion of port entry fees; however, Evergreen and HMM are not expected to pay any fees as they do not own Chinese-built vessels. Most shipping companies, including COSCO, have adjusted their fleet deployments starting from July to minimize port entry fees for Chinese-built vessels.

<Estimated USTR Port Entry Fees by Shipping Carriers>
(Unit: USD million) As of September 2025
Source : Alphaliner (2025), Edited by Author

Operators are primarily responsible for the USTR's port entry fees, but when the operator cannot be identified or the legal entity is unclear in cases of chartering, the registered owner becomes liable for payment. In this context, Seaspan, the world's largest ship owner, is currently headquartered in Hong Kong and is analyzed to potentially pay approximately $1.31 billion in port entry fees as of 2026. Consequently, it has been reported that Seaspan plans to relocate its headquarters to Singapore to avoid regulations, demonstrating an impact on the various participants comprising the container shipping industry.

Automobile carrier ships are mostly not built in the United States, so vessels entering U.S. ports are charged $46 per net ton. When converted to a 6,500 CEU, this results in a burden of $1.15 million per entry, which is similar to the $150 per CEU charge that was introduced in April.

3. China’s Response

China announced countermeasures on October 10, 2025, in response to the U.S. imposition of port entry fees. These measures, in terms of effective date and imposition method, are similar to those proposed by the USTR, and it is expected that Matson, a U.S.-flagged ocean carrier, will be directly affected. Approximately 37% of the volume of cargo handled by Matson is generated from the China-US service. However, the U.S. merchant fleet accounts for merely 0.4% of the global fleet, so the impact on the U.S. carriers is projected to be relatively low compared to Chinese carriers. China’s port entry fee targets companies with U.S. ownership of 25% or more, and it is expected that listed U.S. carriers, such as ZIM, will also be subject to these fees. In China’s case, there are no exemption clauses for vessels built outside of China, and for Very Large Crude Carriers (VLCC), there is an additional cost of about $6 million upon entry, while for Capsize vessels, the additional cost is about $5 million.

4. Future Outlook

It is expected that the impact will not be significant for flag carriers subject to the USTR's proposed port entry fee, as few have the ownership and operational structures targeted by this regulation. However, in the case of car carriers, a rate of over one million dollars per entry is expected to be imposed, leading to increased costs for both carriers and shippers. Currently, global container lines have announced that they will not pass on additional surcharges due to port fees to shippers, but if sea freight rates remain below the break-even point for an extended period, the possibility of passing these costs onto shippers cannot be ruled out.

The container service has already been addressed, but in the long term, the Asia-U.S. supply chain may undergo some changes. In fact, due to the port call fees imposed by China, Maersk's U.S.-flagged vessels have changed their port of call from Ningbo Port to Busan Port. As a result of the redeployment of vessels on the China-U.S. route, there may be changes in the supply.

National shipping companies need to reconsider the ownership structure, operating entities, and construction countries of their vessels due to the imposition of port entry fees between the US and China, and in particular, for vessels entering Chinese ports, they should clearly specify the “port fee responsibility” clause in the charter party contract conditions.

Carriers need to review their shipbuilding and registration strategies to minimize the costs arising from US-China conflicts. For example, in the case of ships that can enter the United States, they can consider building ships in countries other than China or deploying ships of a size that can take advantage of economies of scale to reduce the number of entries into the United States. Shippers need to find ways to diversify their supply chains to spread the impact if the US-China conflict is prolonged. The recent China+1 strategy, which seeks alternatives to China, is a representative example.

Recently, due to the U.S.-China summit, it was announced that the imposition of port entry fees would be postponed for one year; however, the aforementioned postponement may be altered according to the "SHIPS for America Act: Shipbuilding and Harbor Infrastructure for Prosperity and Security for America Act of 2025," which was reintroduced in the U.S. Congress in April this year. Therefore, it is time for both ocean carriers and shippers to prepare for the passage of the related bill.

- Alphaliner(2025), The weekly container shipping newsletter, no.39
   KMI(2024), 미국의 신해양전략이 해운･조선산업에 미치는 영향
- https://ustr.gov/
- https://mykn.kuehne-nagel.com/news/article/ustr-fees-could-impact-35-of-key-sectors
- https://www.bimco.org/media/svdbvnfy/announcement-of-the-ministry-of-transport-of-prc-on-imposing-special-port-fees-on-us-vessels-eng-ver.pdf
- https://www.shippingnewsnet.com/news/articleView.html?idxno=67088

Associate Researcher
/ General Manager

Gun Woo Choi

Currnet) Director of the Maritime Logistics and Shipping Policy Research Office at the Korea Maritime Institute

Past) General Manager, Maritime Financial Research Center, Korea Maritime

Past) Researcher, Port Research Center, Korea Maritime Institute

Current) Director of the Maritime Logistics
and Shipping Policy Research Office
at the Korea Maritime Institute

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