Update 13 November 2025
As of 10 November 2025, the USTR officially suspended the implementation of the service fees on Chinese-linked vessels. The suspension is effective until 9 November 2026. The unpublished USTR Notice of Modification is available here.
No party will accrue liability for or be required to pay the fees on maritime transport services under Annexes I, II or III of the initial USTR Notice of Action during the suspension period. Annex IV providing certain restrictions on LNG transport services has not been permanently suspended, the restrictions are still planned to take effect starting April 2028.
The one-year suspension is the result of ongoing bilateral trade negotiations between the US and China. The Chinese reciprocal Special Port Fees on US vessels have also been suspended for one year.
US Customs and Border Protection (CBP) issued its first guidance early October on the payment of the new service fees for vessels owned or operated by Chinese entities, built in China, and for all non-US built vehicle carriers. The first fees will be implemented on 14 October 2025.
Who will be responsible for paying the fees?
The operator of the vessel will be responsible for paying the fees on the US Department of the Treasury’s secure website pay.gov. The fees cannot be paid at the port of entry.
When should the fees be paid?
The applicable fees must be paid on or before the entry of the vessel at the first US port or place from outside the Customs territory on a particular voyage. CBP strongly encourage responsible parties to pay the fees prior to vessel arrival in the US as vessels without proof of payment will be subject to denial of loading or unloading operations, or granting of clearance withheld, until proof of payment can be verified. It is recommended to initiate payment (on pay.gov) at least three business days in advance of vessel arrival.
Who is responsible for determining the application of the fees?
CBP advised that the operator of the vessel bears the burden for determining if a vessel owes a fee, not CBP.
The text of the full 3 October 2025 CBP guidance is available here.
CBP Area Port Houston/Galveston also issued a Trade Information Notice (TIN) on 6 October 2025. The TIN #66448963 is accessible here. Of importance to members, the TIN clarifies that:
- The vessel owner(s) will be determined by the vessels Registry (REG).
- The vessel operator will be verified through review of the Certificate of Financial Responsibility (COFR). Ports may also request other verifiable agreements like a Bridge Letter or Continuous Synopsis (CSR).
- Net tonnage will be determined by the vessels International Tonnage Certificate (ITC).
- Annex III fees set at $14 per net ton will apply to all foreign-built vehicle carriers or roll-on/roll-off vessels.
For more information on the Section 301 Service fees, we refer members to Skuld’s previous article accessible here. For additional questions, members are encouraged to reach out to their usual claims handlers or the New York claims teams.