The Section 301 restrictive measures proposed by the United States targeting China’s maritime, logistics, and shipbuilding industries are, in essence, an extension of trade disputes.
On October 14, the Office of the United States Trade Representative (USTR) announced the “Action and Proposed Action Announcement” (USTR Port Fee) regarding the “Report on the Investigation of China’s Acts, Policies, and Practices Targeting the Maritime, Logistics, and Shipbuilding Sectors for Dominance,” initiating the first phase of fee collection.
Recently, several liner companies, including Mediterranean Shipping Company (MSC), Maersk, CMA CGM, COSCO Shipping Lines, and Orient Overseas Container Line, have publicly responded to this additional fee. In their responses, these companies clearly stated that the USTR port fee will have a significant impact and pose challenges to their operations. However, they have currently maintained their U.S. route network operations while ensuring compliance through methods such as network restructuring and fleet adjustments. These companies also emphasized that they will not pass this cost on to customers and will maintain freight rates and surcharge levels commensurate with market standards.
However, since the U.S. announced this fee policy, liner companies involved in U.S. trade routes have made multiple adjustments. Currently, some adjustment measures can mitigate the impact of this policy but cannot completely avoid the additional costs, posing a particular test for Chinese operators.
The “Three Noes” Policy Exhibits Characteristics of “Shooting the Arrow First, Then Drawing the Target”
The U.S. imposition of additional fees on vessels operated by Chinese operators or owned by Chinese entities is not an isolated incident but an extension of its trade protectionism into the shipping sector.
The formulation process and subsequent implementation plan of this policy, similar to the U.S. tariff hikes in the trade arena, exhibit typical “Three Noes” characteristics—”no support from international rules,” “no factual basis,” and “inability to achieve the ultimate goal”—as well as the feature of “shooting the arrow first, then drawing the target,” characterized by a lack of thorough论证, phased escalation, and dynamic expansion of the scope of impact.
Calculation of U.S. Route Single-Voyage Fees for Vessels Operated by Chinese Shipowners
According to the USTR announcement, the first phase (implemented on October 14) will target Chinese shipowners and operators, charging a fee based on net tonnage per call at a U.S. port, with annual increases thereafter; target vessels built in China, charging a fee based on net tonnage or container capacity, with annual increases thereafter; and target non-U.S.-built car carriers, charging a fee based on capacity.
From the perspective of actual operational models, container ships typically operate on fixed routes with weekly scheduled services, requiring frequent calls at multiple ports, involving phased fee collection. Furthermore, the freight per container needs to be allocated based on the port of origin and destination. Therefore, the impact of this policy on the container shipping sector is significantly higher than on other ship types.
Additionally, data released by Clarksons shows that among the global operating fleet, the proportion of container ships built in China is approximately 39%. Regarding newbuildings, Chinese shipyards currently have an orderbook of 701 container ships, totaling 6.94 million TEU, representing a market share of about 74% in terms of capacity.
Therefore, the ultimate target of this U.S. policy is China’s shipbuilding industry, but the impact falls squarely on vessel operators, especially for shipping companies from Mainland China involved in U.S. trade routes. This is because even when operating vessels built in other countries on U.S. routes, Chinese companies will still face an additional fee starting at $50/NT initially, rising to $/NT by 2028.
Liner Companies’ Operating Costs Increase Significantly
As one of the world’s busiest trade routes, the sea freight corridor between China and the U.S. handles a large volume of goods such as electronic products, machinery equipment, and textiles. The imposition of additional fees by the U.S. directly leads to a significant increase in the operating costs of liner companies.
According to calculations by CITIC Futures, taking a mainstream 10,000 TEU container ship on the U.S. route as an example, based on the fee standards proposed by the U.S., the initial fee per voyage for a non-Chinese liner company using a China-built vessel would be $/TEU, rising to $/TEU by 2028. However, for vessels operated by Chinese liner companies, the initial fee would be approximately $/TEU, rising to $/TEU by 2028. Calculated based on a maximum of 5 collections per year, the initial maximum annual fee would be $/TEU, which clearly imposes a heavy financial burden on enterprises.
Faced with this policy, the industry previously proposed countermeasures such as transshipment and vessel reallocation within alliances. However, upon in-depth analysis, it is clear that these measures often address the symptoms rather than the root cause and may even create new problems.
The transshipment scheme involves shipping goods originally destined for direct U.S. routes first to a port in a third country or region, and then to a U.S. port via another vessel, to avoid the fees levied on vessels of Chinese entities. However, the transshipment scheme would significantly increase logistics time. Taking the route from Shanghai Port, China, to Los Angeles Port, U.S.A., as an example, direct fast vessels typically take 12-14 days. If transshipment at both ends is chosen, the entire transport process would increase by 3-5 days, which is extremely unfavorable for time-sensitive goods like perishable food and electronic products.
Simultaneously, transshipment incurs additional costs such as port handling fees, storage fees, and transshipment service charges. These costs would ultimately be passed on to the liner companies or shippers, further increasing logistics costs. Estimates suggest that adopting the transshipment scheme would increase logistics costs by $200-$/TEU, making the cost disadvantage of the relevant liner companies even more pronounced in market competition.
Reallocating vessels within alliances is another proposed countermeasure.
Currently, the global shipping market has formed a main operational structure consisting of the Ocean Alliance, the Gemini cooperation, the Premier Alliance, and MSC’s independent operational network. Theoretically, by reallocating vessels within the alliance that are not owned by Chinese entities or not built in China to handle transport tasks, the additional fees could be avoided. However, in practice, this scheme faces many limitations.
On one hand, vessel reallocation within a shipping alliance needs to follow alliance agreements and route planning. Vessel operations and scheduling have a certain degree of planning and stability. Temporary vessel reallocation would disrupt the original operational arrangements and affect the overall operational efficiency of the alliance. On the other hand, the number of vessels within the alliance not owned by Chinese entities is limited, and these vessels also have their fixed transport tasks, making it difficult to meet capacity demands.
Data shows that vessels within the Ocean Alliance not owned by Chinese entities and suitable for Transpacific route transport account for only about 35% of the alliance’s total capacity, far from meeting the alliance’s capacity needs on the U.S. routes. Therefore, the measure of reallocating vessels within alliances is unlikely to fundamentally solve the challenges posed by the U.S. surcharge policy.
Whether through transshipment or alliance vessel reallocation, the final outcome will be increased costs for Chinese liner companies. If these costs are ultimately passed on to shippers, it will not only weaken the competitiveness of liner companies in the global shipping market but also increase the logistics costs of the entire industrial chain. According to industry predictions, affected by this policy, Chinese shipping enterprises could face additional port fees amounting to billions of dollars over the next year if they wish to maintain their current scale on U.S. routes. Under the current freight rate trends, this could even lead to losses.
An Imbalanced Landscape: A Huge Gap Between Supply and Demand
As the world’s second-largest economy and the largest trader in goods, China’s import and export scale has ranked among the top globally for many years. In 2024, China’s total import and export value of goods reached 43.85 trillion RMB, a year-on-year increase of 5%, accounting for approximately 12.5% of the global total trade in goods. China’s import and export trade has not only made significant contributions to global economic growth but also generated huge demand for the global shipping market.
However, what does not match China’s massive import and export trade scale is that the status of China’s shipping industry in the global shipping market still has significant room for improvement. Especially in the container shipping sector, there remains a gap between the capacity share of Chinese liner companies and that of European liner companies.
In terms of the global liner company capacity share, as of September 2025, among the top 20 global liner companies, the four companies headquartered in Europe—MSC, Maersk, CMA CGM, and Hapag-Lloyd—collectively hold a capacity share of 54.5%, and all operate global routes. In contrast, among Mainland Chinese companies, only COSCO Shipping operates global routes, with a capacity share of 10.6%. Adding SITC, which operates in regional markets, the total share is only 11.2%, approximately one-fifth that of the European liner companies.
Capacity Share and Location of the Top Twenty Global Liner Companies
This disparity in capacity share, combined with long-standing factors such as China’s trade exports exceeding imports, has directly led to Chinese shippers and Chinese shipping enterprises being relatively passive in pricing during the transportation segment of export trade.
In the international shipping market, freight rate setting is often determined by dominant shipping enterprises. European liner companies, by virtue of their massive capacity scale and market share, hold significant pricing power in setting freight rates.
Taking the US route freight rates as an example, in 2023, against the backdrop of global supply chain tensions, European liner companies repeatedly led freight rate increases. This not only increased the transportation costs for Chinese shippers but also squeezed the profit margins of Chinese manufacturing enterprises, significantly impacting the “going global” process of Chinese manufacturing.
Furthermore, the unequal relationship in trade terms also weakens the supply chain control capability of Chinese trade enterprises.
In international goods trade, trade terms typically include transportation responsibility, risk transfer, and freight payment. Currently, in trade contracts between China and its major trading partners like the United States and Europe, the proportion using FOB (Free On Board) trade terms is relatively high, while the proportion using CIF (Cost, Insurance and Freight) or CNF (Cost and Freight) trade terms is relatively low.
Under FOB terms, the responsibility for goods transportation and freight payment is borne by the buyer. The buyer will主导 (dominate) the choice of carrier and control the entire transportation process, which is commonly referred to in the industry as “指定货” (designated cargo). Chinese trade enterprises can only passively accept the logistics services chosen by the buyer and cannot effectively control the transportation segment. This places Chinese trade enterprises in a weak position within the supply chain. Once issues like delays or cargo damage occur, they often face significant losses but find it difficult to protect their legitimate rights and interests. Adopting CIF or CNF terms allows effective mastery of the initiative in the transportation segment, enabling independent selection of logistics suppliers, control over transportation costs and time, and ensuring supply chain stability.
This inequality in trade terms further exacerbates the imbalance between the development of China’s shipping industry and its import-export trade, and also indicates that there is still significant room for improvement in China’s position within the global supply chain.
Multiple Parties Offer Suggestions to Create a Stable Environment for Shipping Enterprises
Several industry experts, interviewed by China Shipping Gazette reporters, stated that in the face of challenges posed by the US imposing surcharges on Chinese shipping enterprises, and the imbalance between the development of China’s shipping industry and its import-export trade, they recommend that government departments actively take measures to create a favorable policy environment and international competitive environment for the development of China’s shipping industry.
First, it is recommended that the competent commerce authorities incorporate the US Section 301 investigation into China’s maritime sector into the overall process of Sino-US trade negotiations.
The Section 301 restrictive measures proposed by the US targeting China’s maritime, logistics, and shipbuilding industries are essentially an extension of trade disputes, attempting to implement “precision strikes” on key sectors to curb the development of China’s import-export trade and the “going global” process of Chinese manufacturing. Currently, over 80% of global import-export trade transportation is completed by shipping, making shipping the mode of transportation most closely associated with import-export trade.
Therefore, it is suggested to incorporate the Section 301 investigation in the maritime sector into the overall process of Sino-US trade negotiations, binding trade and maritime clauses together for negotiation. It is recommended that the Chinese government clearly express its stance and demands in the maritime sector during Sino-US trade negotiations, requiring the US to cancel unreasonable restrictive measures such as surcharges on Chinese shipping enterprises and to stop discriminatory treatment against Chinese enterprises in the maritime sector.
Simultaneously, it is recommended that relevant departments unite with other countries and regions affected by US trade protectionism, especially the home countries of affected shipping enterprises, to lodge complaints and resist the US’s unreasonable policies within multilateral trade frameworks such as the World Trade Organization (WTO), safeguarding the fair competition order of the global shipping market and the multilateral trading system. Through multilateral cooperation and negotiation, form a joint force to compel the US to change its trade protectionist practices in the maritime sector and strive for a fair international competitive environment for Chinese shipping enterprises.
Second, it is recommended to promote the transformation of trade terms and the expansion of shipping enterprises’ capacity scale through policy guidance.
Specifically, efforts can be made from the following aspects: First, strengthen publicity and training for Chinese trade enterprises and manufacturing enterprises, enabling them to fully recognize the importance of adopting CIF and CNF terms for controlling the supply chain, reducing transportation costs, and avoiding transportation risks, thereby enhancing their awareness to proactively choose advantageous trade terms. Second, introduce relevant incentive policies, offering certain preferences in areas such as export tax rebates, credit support, and government subsidies to enterprises that adopt CIF and CNF terms, encouraging enterprises to actively transform. Third, establish and improve a trade term service system, providing enterprises with services like trade term consultation and negotiation guidance, helping them better strive for favorable trade terms during trade contract negotiations.
Third, it is recommended that competent authorities increase policy support to assist Chinese shipping enterprises in expanding their capacity scale. By upgrading for environmental protection, renewing ship equipment, improving ship technology levels, and enhancing operational efficiency, the market competitiveness of Chinese shipping enterprises can be strengthened.
Finally, it is recommended that relevant departments take reciprocal countermeasures when necessary.
In situations where Sino-US trade negotiations and multilateral engagements fail to make effective progress, and the US insists on implementing unreasonable policies such as surcharges on Chinese shipping enterprises, it is recommended that relevant departments consider adopting reciprocal countermeasures to safeguard China’s legitimate rights and interests and the fair order of the global shipping market.
When formulating reciprocal countermeasures, it is recommended to fully consider international practices and China’s actual situation, ensuring the legality, rationality, and appropriateness of the countermeasures. At the same time, strengthen communication and coordination with other countries and regions, explaining to the international community the reasons and purposes behind China’s countermeasures, striving for international understanding and support, and avoiding unnecessary trade friction and conflict.
By taking reciprocal countermeasures, China can convey its firm resolve to safeguard its own rights and interests, compelling the US to re-examine its maritime policies towards China and creating a fair international competitive environment for Chinese shipping enterprises.
