โ€œPay Before You Berthโ€ CBP Locks In New U.S. Fees for China-Linked Ships

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Starting October 14, 2025, U.S. Customs and Border Protection (CBP) will enforce new Section 301 port-entry fees on vessels that are Chinese-owned/operated (Annex I) and on Chinese-built ships (Annex II), with payment due before arrival and the operator responsible for determining liability. CBP says vessels without proof of payment risk denial of lading/unlading or withheld clearance; it โ€œstrongly recommendsโ€ initiating payment ~3 business days ahead of the call. Annex I begins at $50 per net ton and steps up annually through 2028; analysts estimate per-call exposure can exceed $1M on large boxships.

Heads-up: Policies, fees, and enforcement guidance can change quickly. Confirm current requirements with official CBP notices, carrier advisories, and terminal agents before acting.
US Port Fees on China-Linked Ships: Industry P&L Impact
Story Impact Business Mechanics Bottom-Line Effect
Effective date & operator liability Fees apply to qualifying vessels calling the US from Oct 14, 2025; the operator must determine and pay. Set up Pay.gov workflows and internal checklists to assess vessel status (ownership/operation/build) for each call. ๐Ÿ“‰ New recurring per-call cash outflow; ๐Ÿ“ˆ admin workload to prove determinations.
Scope โ€” who pays Annex I: Chinese-owned/operated vessels. Annex II: Chinese-built vessels (even when non-Chinese operated). Flag/status checks, build yard verification, charter chain disclosures, and records aligning with CBP guidance. ๐Ÿ“‰ Wider fleet exposure than ownership alone; mixed fleets face more frequent hits.
Rates & escalation schedule Annex I starts at $50/NT and steps up annually through 2028 (published schedule). Budget multi-year increases; revisit US call economics and vessel assignment as fees rise. ๐Ÿ“‰ Growing cost curve; earlier route redesigns mitigate compounding exposure.
Payment timing & enforcement CBP urges payment before arrival; without proof, lading/unlading may be denied or clearance withheld. Initiate payment ~3 business days prior to ETA; retain proof and agent confirmations. ๐Ÿ“‰ Delay risk becomes cost (idle time, missed windows) if payment isnโ€™t verified in time.
Illustrative exposure (large boxships) Analyst estimates show seven-figure per-call exposure on high-capacity ships. Stress-test calls for 10k+ TEU vessels; compare with alternative vessel assignments or port pairs. ๐Ÿ“‰ Margin squeeze if unrecovered; ๐Ÿ“ˆ incentive to shift hull mix on US strings.
Contracts & surcharges Carriers likely deploy fee recovery surcharges on affected US legs. Amend tariffs; align BCO/NVO contracts for pass-through; track competitive price elasticity. ๐Ÿ“ˆ Revenue protection for carriers if surcharges hold; ๐Ÿ“‰ higher landed cost for cargo owners.
Network & routing implications Operators may reassign non-exposed hulls to US services; exposed vessels pivot to other trades. Model loop redesigns, transshipment shifts, and call reductions where fee impact is heaviest. โ†” Lane capacity mix changes; ๐Ÿ“‰ possible schedule reshuffles and knock-on costs.
Documentation, audits, & proof Higher scrutiny on ownership chains, build documentation, and evidence of payment. Maintain yard certificates, charterparty disclosures, Pay.gov receipts, and agent attestations. โ†” Compliance cost up; ๐Ÿ“ˆ reduces risk of operational holds and penalties.
Time-charters & third-party tonnage Operators on-hire vessels still bear the fee determination and payment burden. Embed fee clauses in COAs/charters; ensure counterparties supply build/ownership data. ๐Ÿ“‰ Unbudgeted charges if terms are silent; ๐Ÿ“ˆ recoverability improves with clear language.
Market ripple & competitiveness Non-exposed fleets gain a relative cost edge on US legs. Expect sales outreach around โ€œcleanโ€ rotations; watch share shifts on certain trades. ๐Ÿ“ˆ Potential volume gains for exempt operators; ๐Ÿ“‰ exposed operators face tender headwinds.
Note: Summary reflects CBP guidance and trade reports. Specific fee computations depend on vessel characteristics and the applicable Annex at time of call.
๐Ÿ“ˆ Winners ๐Ÿ“‰ Losers
  • Operators with exempt fleets/rotations: relative cost edge on US legs where Annex exposure is zero.
  • BCOs/NVOs contracted with exempt carriers: fewer fee pass-throughs and lower landed-cost volatility.
  • Korean/Japanese/European newbuild yards: preference shift toward non-Chinese builds on US services.
  • Compliance-savvy agents and advisors: demand for liability determinations, documentation, and audit trails.
  • Banks/insurers with strong KYC frameworks: increased appetite for counterparties with clean ownership/build proofs.
  • Data providers & registries: higher value for verified build yard, ownership, and operator records.
  • Ports and terminals with streamlined pre-arrival checks: faster greenlights attract calls from fee-ready operators.
  • Carriers with flexible fleet assignment: ability to swap in exempt hulls to preserve US loops and yields.
  • Chinese-owned/operated vessels (Annex I) on US calls: recurring per-call fees and heightened scrutiny.
  • Chinese-built vessels (Annex II) regardless of operator: broader net of liability; difficult to avoid without reassignment.
  • Time-charterers lacking pass-through clauses: unbudgeted charges where contracts are silent.
  • Spot shippers on exposed services: fee recovery surcharges, higher premiums, and routing uncertainties.
  • Mixed-fleet carriers with heavy Annex exposure: complex rotations, admin overhead, and margin pressure.
  • Late payers or documentation-light operators: risk of delayed clearance, idle time, and missed berthing windows.
  • Procurement teams tied to Chinese yard deliveries: long-tail fee exposure on otherwise competitive tonnage.
  • Trade lanes with few exempt alternatives: reduced competition and higher all-in costs for cargo moving to/from the US.
Annex Finder โ€” What Triggers a Fee?
Annex I
Chinese-owned or Chinese-operated vessels
  • Applies based on owner/operator status
  • Operator responsible for determination & payment
  • Fee due prior to US arrival
Annex II
Chinese-built vessels (yard of build)
  • Applies even if non-Chinese owned/operated
  • Build documentation and class records are key
  • Fee due prior to US arrival
Start date: Oct 14, 2025 ยท CBP indicates operator liability and pre-arrival payment with proof at the call.
Pre-Arrival Payment Timeline (illustrates sequencing)
T-4 to T-3 business days T-2 business days T-1 business day Day of arrival
Confirm Annex status (owner/operator/build) Initiate payment on the designated portal Distribute proof of payment to agent & terminal Present evidence if requested; proceed with lading/unlading
Exposure Examples
Situation Likely Annex Exposure note
Chinese-owned ship under time charter to non-Chinese operator Annex I Operator pays despite charter; contract language critical
Non-Chinese owner/operator on a hull built at a Chinese yard Annex II Build yard triggers liability even with โ€œcleanโ€ ownership
Mixed fleet on US loop (some Annex I/II, some exempt) Mixed Assignments determine per-call exposure and surcharge need
Documents & Data Pack Typically Reviewed
Ownership & operator declarations Shipyard certificate / build evidence Class & registry extracts Charterparty clauses (fees/pass-through) Payment receipt & reference Agent/terminal confirmations
Operational Hold Triggers
No proof of payment on arrival Unclear owner/operator status Disputed yard-of-build records Late payment initiation vs ETA Mismatched charter disclosures
Relative Cost Edge on US Calls (Qualitative)
Fleet Type Fee Exposure Commercial Angle
Exempt fleet (non-Chinese build & ownership) Low Pitch cost stability; potential share gains
Chinese-built but non-Chinese owned/operated Medium (Annex II) Consider reassignment or surcharge recovery
Chinese-owned/operated High (Annex I) Budget per-call fee; strengthen documentation flow
Contract Touchpoints to Watch
Area Description
Fee pass-through clauses Clarifies who pays and how recovery is applied on US legs
Information covenants Ensures timely owner/operator/build disclosures
Change-in-law/tariff provisions Provides a basis for adjustments if the regime evolves

The new fee regime changes voyage math on US calls where Annex I or II applies. The near-term P&L effect comes from pre-arrival cash outlays, tighter documentation workflows, and potential schedule friction if proofs arenโ€™t aligned at the berth. Fleets with clean ownership/build profiles gain a relative edge, while mixed or exposed fleets will look to reassign hulls or pass through costs where market conditions allow.

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