Update: Guidance on the implementation of the China Special Port Fees effective 14 October 2025

Update 4 November 2025

The White House announced that enforcement of the USTR service fees will be suspended on 10 November 2025.

Special update 30 October 2025

In a significant diplomatic development, US President Donald Trump and Chinese Premier Xi Jinping have decided to suspend reciprocal port charges for one year following a meeting in South Korea on Thursday 30 October 2025.

Update 22 October 2025

Skuld has received advice indicating that time and voyage charterers might be classified as "operators" under the Implementation Measures. The term "operator" in Chinese law could extend to any entity that exerts effective control over operational decisions, including routes, berthing, loading, and unloading. If this interpretation holds, the definition of "operator" would be significantly broadened, leading to extensive implications.

Both articles concerning China Special Port Fees have been updated. Additionally, new sections have been incorporated, detailing actions members can take if vessel entry or clearance is denied and explaining International Ship Transport License.

Background

Following yesterday’s Skuld article about Announcement 54, the Chinese Ministry of Transport has released the Implementation Measures regarding Special Port Fees for US vessels. Skuld thanks Wang Jing & Co for their guidance, including detailed instructions for completing the “Reporting Form of U.S.-Linked Vessel Information.” Members are encouraged to review their full article via the link below.

Brief highlights of the implementation measures

Vessels caught in any of the categories listed below must pay Special Port Fees (See Skuld article 13 October 2025).

How will the Special Port Fees be collected?

The maritime administration at the vessel’s port of call collects the Special Port Fees. For vessels visiting multiple Chinese ports on one voyage, charges are collected only at the first port; no additional charges apply at later ports.

What if a vessel makes six or more calls a year?

For vessels visiting Chinese ports over five times a year, Special Port Fees apply only to the first five calls; further visits are exempt upon proof of prior payment. No vessel is charged for more than five voyages per year, with the annual billing cycle beginning on 17 April 2026.

When is information to be submitted?

The owner or operator or their agent must at least seven days before arrival at a Chinese port—or upon departure if the voyage is under seven days—report to the maritime administration information on the vessel’s country of construction, flag state, owners, operators, leasing details, intended ports of call, via the “China International Trade Single Window” platform and pay the required Special Port Fees. For detailed reporting guidance please refer to the article by Wang Jing & Co link below.

What penalties apply if the information is incorrect?

At this stage, the penalties appear to be less severe than previously anticipated by Skuld. Skuld has been informed that if the information is not provided, the maritime authority will request the agent or owner/operator to correct or supply the relevant information.

What happens if payment is not made and the vessel leaves?

If Special Port Fees are not paid, vessel entry or clearance may be denied. If the vessel departs China without payment, it will be required to pay these charges on its next visit to China.

Will the Special Port Fees apply to US nexus time and voyage charterers?

Currently, Special Port Fees do not appear to apply to voyage or time charters. However, they are likely to apply to bareboat charterers. No specific guidance has been provided on this matter, and the situation may continue to develop in the coming weeks.

However, members are advised that this is a complicated area and that legal advice should be sought if members may fall into one of the categories, particularly category 3, or are a NVOCC and or ..’’companies holding an International Ship Transport License under the Regulations on International Maritime Transport.”

The “International Ship Transport Licence” is one of the licenses that granted by the MOT to Chinese companies to allow them to operate in the international carriage of passengers or liquified chemical cargo businesses, which are entry-restricted regulated by the PRC International Maritime Regulations. Similarly, under this regulation, “International Liner Operators” and “NVOCCs” (including foreign companies) should register themselves with the authority before they can operate in Chinese ports.

Update 22 October 2025
Skuld has recently been advised that there is a possibility that voyage charterers and time charterers may also be considered as “operators” under the Implementation Measures, as the definition of an “operator” under Chinese law may also include any entity exercising effective control over operational decisions such as routes, berthing, loading and unloading. If this interpretation is confirmed, the scope of entities falling under the definition of “operator” could be quite broad, potentially resulting in far-reaching implications.’’ Members seeking assistance on this should reach out to their personal claims handler.

Are there any exemptions to the Special Port Fees?

Please refer to the table above. Additionally, unladen vessels entering Chinese shipyards solely for repairs, and other vessels that are recognised and approved for exemption, are also not required to pay. Wang Jing & Co noted in their article that while ‘’other vessels that are recognised and approved for exemption’’ is not clearly defined, it may allow vessels needing emergency assistance or conducting humanitarian relief to request an exemption from the Maritime Authorities.

What should an owner/operator do if the vessel is denied entry or clearance?

As mentioned above, if the Special Port Fees are not paid, the vessel may be denied entry or clearance. There is no guidance yet on what to do if a vessel is denied entry or clearance. However, as a practical step, if members wish to demonstrate that the vessel should not be subject to the Special Port Fees, members could submit the following documents through their local agent:

1. Vessel documentation – Certificate of Registry, DOC, SMC, CSR and other statutory certificates; bareboat charterparty (if any); ship management agreement.

2. Corporate registration documents – Business licences or certificates of incorporation for the owner, manager, and bareboat charterer (if any), and their direct or controlling shareholders; evidence of principal place of business and registered headquarters.

3. Shareholding and governance documents – Memorandum of Association, Article of Association, Shareholders’ agreements, Articles of Association, shareholder registers, etc., and shareholding ratio tables.

4. Ownership and control documents – Detailed structure charts tracing ownership to the ultimate natural persons; ID or registration documents for beneficial owners; proof of voting arrangements, convertible securities, and control agreements (e.g. VIE, voting proxy, board appointment agreements).

5. Governance information – List of board members with documents showing appointment rights; list of executive officers and appointment authority, and the proof of their nationality.

6. Financial information – The last two years audited financial statements, and bank KYC/due diligence summaries, etc.

7. Statement of Non-Applicability – An explanatory statement by the owners, summarising the above evidence and asserting that the vessel does not fall within the scope of vessels subject to the Special Port Fees.

The above is for reference only, and Skuld advises members that if the vessel is denied entry and or clearance, to reach out to their usual claims handlers and seek specialist legal advice from recommended Chinese lawyers. Delays to the vessel should be anticipated if the vessel is denied entry and or clearance.

Further assistance

Skuld global claims handlers are monitoring developments. Members should reach out to their claims handlers if assistance is required.

Acknowledgements

John Wang, Wang & Jing & Co