Recently, COSCO Shipping Lines issued a “Notice to Customers Regarding the USTR Section 301 Investigation,” addressing market concerns over the U.S. Trade Representative (USTR) port fee policy. The policy, which will take effect less than a month later on October 14, 2025, will impose fees on Chinese operators and shipowners, as well as operators using Chinese-built vessels.
COSCO Shipping Lines stated: “While the port service fees may pose certain operational challenges, COSCO SHIPPING Linesremains confident in our ability to ensure stable and reliable services in the United States. We arecommitted to maintaining stable capacity deployment and service quality, consistently deliveringreliable,secure,and high-quality logistics solutions. Concurrently, the company will actively refine its product portfolio to adapt to the evolving demands of the U.S. market, while maintaining competitive freight rates and surcharges aligned with prevailing market levels.”
Several major shipping companies have already responded to the USTR’s port fee policy.
Recently, Mediterranean Shipping Company (MSC) has signaled to its customers that it will absorb these costs internally without passing them on to clients. In a customer notice, MSC CEO Soren Toft stated that the company has “proactively restructured its global vessel deployment network, implementing internal adjustments to ensure full compliance with U.S. trade regulations while maintaining the reliability and efficiency of MSC services.”
French shipping giant CMA CGM announced on September 10 that it is fully prepared and has taken necessary measures to implement its adaptive contingency plan within the 180-day grace period following the USTR notice. The company will not impose any USTR-related surcharges on shipments destined for the United States. The company stated in its announcement: “While the port fee policies present operational challenges, based on the current structure and applicability of service charges, the company has no plans at this time to implement surcharges to cover USTR-related costs under the existing framework.”
Earlier in August, at a supply chain meeting, Maersk executive Anders Sonesson revealed Maersk’s response to USTR port fees: it does not intend to charge customers surcharges to cover the additional costs. Maersk will prioritize rerouting routes to avoid the potential additional costs. “If calling at a US port costs millions of dollars, we will not allow any Chinese-built vessels to operate on US routes. We expect our other competitors and alliances to do the same.”
Port fees will have a significant impact on Chinese shipping companies.
Following a year-long Section 301 investigation and extensive public consultation, the USTR announced this port fee package in April this year.
The fee structure operates on two tiers:
Taking the typical 50,000-TEU container ships commonly operated by COSCO Shipping and OOCL on trans-Pacific routes as an example, the initial cost per voyage has reached $2.5 million. This figure is projected to climb to $4 million by 2026, reach $5.5 million in 2027, and peak above $7 million by 2028.
HSBC analysis indicates that these fees will have a significant financial impact on Chinese shipping companies. The bank forecasts that COSCO Shipping will face annual port fees of up to $1.5 billion, equivalent to 74% of its projected 2026 earnings before interest and taxes (EBIT).
OOCL is expected to incur $654 million in fees, representing 65% of its anticipated earnings.
HSBC noted that the fee disparity between Chinese and non-Chinese carriers is quite significant. Non-Chinese carriers only incur charges when deploying Chinese-built vessels calling at U.S. ports, provided they “maintain a sufficient fleet of non-Chinese-built vessels to avoid these fees.” Currently, 71% of global container shipping capacity measured in TEUs is non-Chinese built. Meanwhile, only 15% of tonnage calling at US ports in 2024 utilizes Chinese-built vessels.
Major shipping alliances have begun adjusting their networks.
Major shipping alliances have begun adjusting their route networks. HSBC data indicates that the Premier Alliance plans to split its Mediterranean-South Pacific 2 route into separate services, thereby removing 10 Chinese-built vessels from calling at US ports. Maersk and Hapag-Lloyd have started deploying South Korean-built vessels on transpacific routes.
Chinese shipping companies can adopt potential countermeasures. HSBC recommends that COSCO Shipping and OOCL leverage their Ocean Alliance partnership with CMA CGM and Evergreen Marine to deploy more non-Chinese-built vessels on transpacific routes operated by these non-Chinese partners, while redirecting their own capacity to alternative routes. An alternative approach involves bypassing US ports entirely and instead relying on transshipment services through Canada, Mexico, or the Caribbean.
Routing network adjustments may temporarily tighten shipping capacity. Port fee policies may also delay the scrapping of older non-Chinese-built vessels, which account for 93% of the total container fleet aged over 20 years (representing 12.5% of the global fleet).
Notably, the USTR’s policy includes several key exemptions for vessels owned by the United States, vessels participating in the US Maritime Administration program, small vessels, ballast vessels, vessels engaged in short-sea shipping trade, and specific dedicated export vessels.
The upcoming port fee standards have been adjusted from the initial proposal. The final plan excludes several earlier suggestions, such as imposing a fixed fee of $1 million to $1.5 million per port call on operators with a large fleet of Chinese-built vessels, as well as penalties based on future orders for Chinese-built vessels.
The second phase of this policy, scheduled for implementation on April 17, 2028, will target the liquefied natural gas (LNG) industry, mandating that a portion of US LNG exports must utilize US-built vessels. Given the limitations in US LNG shipbuilding capacity and expertise, this requirement will be phased in over a 22-year period.
