New Section 301 Fees on Chinese and Foreign-Built Vessels Take Effect October 14
The U.S. government has announced new vessel fees under the ongoing Section 301 action into China’s targeting of the maritime, logistics, and shipbuilding sectors for dominance. Effective October 14, 2025, these fees apply to vessels that are owned, operated, or built in China, as well as to all foreign-built vehicle carriers.
These measures, outlined in the Federal Register Notice of April 17, 2025 (as modified June 12, 2025), mark a significant escalation in U.S. trade actions targeting China’s maritime and logistics industries. The fees are intended to counter what the U.S. Trade Representative (USTR) has described as “unfair Chinese policies and practices” in the global shipbuilding and shipping markets.
What the New Fees Require
Under the final rules, vessel operators—not U.S. Customs and Border Protection (CBP)—are responsible for determining whether the fee applies and for ensuring timely payment. Operators who fail to provide proof of payment before arrival risk denial of lading or unlading operations, and clearance may be withheld until payment can be verified.
It is strongly recommended by CBP that payments be made at least three business days before vessel arrival.
The following fees apply under each Annex:
- Annex I: $50 per net ton for any vessel owned or operated by a Chinese entity.
- Annex II: The higher of $18 per net ton or $120 per container discharged for any vessel built in China.
- Annex III: $14 per net ton for any vehicle carrier or roll-on/roll-off vessel, regardless of country of ownership.
Liquefied Natural Gas (LNG) tankers (vessel type 132) are exempt from these fees.
Payment and Documentation Procedures
Fees must be paid electronically via the Department of the Treasury’s Pay.gov portal using the Section 301 Fee Payment Form. Payments will not be accepted at the port of entry.
The form will require vessel and voyage details, including:
- Vessel name and IMO number
- Arrival port and estimated arrival date
- Voyage number
- Operator and payor contact information
Once submitted, Pay.gov will generate a payment confirmation transmitted to CBP’s Vessel Entrance and Clearance System (VECS). If VECS cannot automatically match the payment, operators may present the confirmation email as proof of payment.
Operators using VECS should review and confirm all entry details and promptly update any changes. Paper filings must be manually reviewed for compliance with the applicable Annex requirements.
Compliance Takeaways for Vessel Operators
- Responsibility rests entirely with the operator to determine applicability and ensure payment.
- Advance payment is critical to avoid clearance delays.
- Review Annex exemptions and potential suspension provisions carefully—these may apply in limited circumstances.
- Maintain documentation of all payments and filings for audit and enforcement purposes.
As new tariff regulations continue to evolve, navigating these changes requires experienced legal counsel. At Liang + Mooney, PLLC, our seasoned tariff lawyers can answer your questions and concerns with sophisticated legal solutions. If you seek strategic counsel and insight into which tariffs apply to your operations, we invite you to contact us to schedule a consultation.