China-Linked Vessel Fees Remain Unsettled: Add a Port-Call Tax Scenario to Ocean Bids
The next ocean freight bid needs a port-fee scenario, even if nobody can yet say whether the fee will survive unchanged.
U.S. fees targeting certain China-linked vessels remain suspended, but the suspension is scheduled to expire November 9, 2026. FreightWaves reports that the charges remain scheduled to resume November 10, despite a broader U.S.-China trade truce running into 2027. That mismatch creates a planning problem: a shipper may sign an annual rate while a material component of the carrier's port-call economics is still unresolved.
The answer is not to add one speculative surcharge to every container. It is to identify which services could create exposure, model how carriers might pass it through, and put dated adjustment rules into the bid.
Treat the suspension as a deadline, not a resolution
The policy grew from the U.S. Trade Representative's Section 301 investigation into China's maritime, logistics, and shipbuilding sectors. Its structure has changed before and could change again. Trade groups are now asking for more time: Supply Chain Dive says nearly 40 trade associations urged the USTR to extend the pause for another year.
The potential exposure is large enough to include in procurement decisions. Supply Chain Dive reports that the scheduled fees can range from $18 per net ton to $120 per container, depending on the applicable category, with increases contemplated in subsequent years. Those figures are not interchangeable rate inputs. They describe different fee structures attached to vessel ownership, operation, construction, and capacity.
Procurement teams should therefore maintain three scenarios through the bid cycle:
- suspension extended with no near-term charge;
- fees resumed under the published structure;
- fees resumed after a revised schedule or set of exemptions.
Give each scenario an owner, a probability range, and a date for review. The November deadline is an operational checkpoint, not a prediction that policy will remain static until then.
Map exposure at the vessel and service-string level
A carrier name alone does not determine whether a sailing is exposed. The relevant facts may include the vessel's builder, registered owner, beneficial owner, operator, fleet composition, capacity, and U.S. port calls. A multinational carrier can operate a mixed fleet across several loops, so a network-wide assumption will distort the bid.
Start with the service strings used by the lanes in scope. For each string, record:
- origin, transshipment, and U.S. destination ports;
- scheduled vessel names and IMO numbers;
- vessel builder and country of construction;
- registered owner and operating entity;
- capacity and expected number of U.S. calls;
- substitution rights and recent vessel-swap frequency.
Then connect that information to forecast container volume. The output should show the portion of demand exposed under each policy category, not merely the number of China-built ships in a carrier's global fleet.
Vessel substitutions deserve their own rule. A bid may appear unexposed when awarded but become exposed when the carrier rotates a different ship into the service. Require carriers to explain how they will notify customers of a qualifying substitution and whether a new charge can begin mid-contract.
Model pass-through instead of inventing one surcharge
The fee may be assessed around a port call or vessel characteristic, while the commercial pass-through may appear per container. Those are different calculations. Model the carrier's likely total liability first, then test allocation methods across loaded imports, exports, empties, and multiple U.S. calls.
For example, a service with high utilization and a large number of chargeable containers can spread a port-call cost differently from a lower-volume service. A carrier may absorb part of the fee, apply a published surcharge, change vessel deployment, skip a port, or alter rotations. Each response changes landed cost or transit reliability.
Build bid comparisons with at least four fields beyond the base rate:
- stated surcharge formula and triggering authority;
- maximum charge per container during the contract term;
- affected services and effective notice period;
- reversal rule if the fee is suspended, reduced, or invalidated.
This prevents a low base rate from winning when its policy language permits an uncapped pass-through. It also avoids penalizing every lane for a risk concentrated in a handful of services.
Put expiry dates into the award
Every scenario needs an expiry date. Ask carriers to hold two price views: the contracted rate under the suspension and the rate or formula that would apply if fees resume. Set review points before November 9 and immediately after any USTR announcement.
Contract language should identify the source document that activates the adjustment, the exact calculation, supporting evidence, and how quickly the surcharge ends when the underlying fee ends. Include a dispute process and the right to shift volume if the total landed-cost increase breaches an agreed threshold.
Operations should prepare as well as procurement. Flag bookings on potentially exposed strings, retain the vessel identity used at booking and departure, and compare invoices with actual port calls. If carriers redesign rotations, measure the resulting transit-time variance, transshipment risk, and inland changes rather than treating the issue only as a tax.
Make uncertainty manageable
The unresolved policy does not justify waiting to bid, and it does not justify inflating every ocean lane. It calls for structured optionality. Vessel-level data identifies where exposure exists; service-string scenarios show its economic effect; dated contract rules determine who acts when policy changes.
CXTMS can connect bid assumptions with bookings, vessel events, accessorials, and invoice validation so a policy change becomes a controlled workflow instead of a surprise surcharge.
See how CXTMS can help your team model ocean cost scenarios and manage exceptions. Request a CXTMS demo.
