301 Action Fee Framework：

On April 17 this year, the Office of the United States Trade Representative (USTR) released the "Notice of Action and Proposed Action in Section 301 Investigation of China’s Targeting the Maritime, Logistics, and Shipbuilding Sectors for Dominance, Request for Comments" (hereinafter referred to as the "Notice"). An annex to the Notice indicated that fees would be temporarily set at zero for 180 days starting from April 17. The first phase of fees will be levied starting from October 14, 2025:

• Tiered increasing fees based on net tonnage for Chinese operators and shipowners.

• Tiered increasing fees based on net tonnage or container volume for Chinese-built vessels.

• Fees based on capacity for foreign-built vehicle carriers.

According to the current fee framework established by the USTR for this action:

1. For Chinese ship operators and Chinese shipowners, subject to the exemptions and special rules of this Annex, on or before the entry of a vessel at the first U.S. port or place from outside the Customs territory on a particular string, the vessel operator must pay:

   Effective as of April 17, 2025, a fee in the amount of $0 per net ton for the arriving vessel

   Effective as of October 14, 2025, a fee in the amount of $50 per net ton for the arriving vessel.

   Effective as of April 17, 2026, a fee in the amount of $80 per net ton for the arriving vessel.

   Effective as of April 17, 2027, a fee in the amount of $110 per net ton for the arriving vessel.

   Effective as of April 17, 2028, a fee in the amount of $140 per net ton for the arriving vessel.

   The fee will be charged up to five times per year, per vessel.

2. For vessel operators (non-Chinese vessel operators) of Chinese-built vessels, they must pay the higher of these two fee calculation methods:

   Effective as of April 17, 2025, a fee in the amount of $0 per net ton for the arriving vessel.

   Effective as of October 14, 2025, a fee in the amount of $18 per net ton for the arriving vessel.

   Effective as of April 17, 2026, a fee in the amount of $23 per net ton for the arriving vessel.

   Effective as of April 17, 2027, a fee in the amount of $28 per net ton for the arriving vessel.

   Effective as of April 17, 2028, a fee in the amount of $33 per net ton for the arriving vessel.

   Or

   Effective as of: April 17, 2025, a fee in the amount of $0 for each container discharged.

   Effective as of: October 14, 2025, a fee in the amount of $120 for each container discharged.

   Effective as of: April 17, 2026, a fee in the amount of $153 for each container discharged.

   Effective as of: April 17, 2027, a fee in the amount of $195 for each container discharged.

   Effective as of: April 17, 2028, a fee in the amount of $250 for each container discharged.

Fee Example：

According to shipping expert Lars Jensen, a COSCO container ship with a capacity of approximately 13,000 TEUs and a net tonnage of about 65,000 tons would, under the $50 per net ton fee standard, be required to pay approximately $ 3.25 million for its first call at a U.S. port once the fees are formally implemented. This translates to about $250 per TEU under full load conditions. Under the same conditions, by 2028, the fee for such a ship would increase to approximately $9.1 million per call, or about $700 per TEU, representing a near tripling of costs over three years.

Policy Background：

China's shipbuilding industry has ranked first globally for 15 consecutive years, while the U.S. shipbuilding industry accounts for only 0.1% of the global market. To revitalize and rebuild its domestic maritime industry and workforce to promote national security and economic prosperity, the U.S. conducted a Section 301 investigation. The report stated that over the past three decades, China has pursued increasingly aggressive specific goals to dominate the maritime, logistics, and shipbuilding sectors, which have placed U.S. companies, workers, and the overall economy at a severe disadvantage by undermining competition and business opportunities, and creating economic security risks through dependency and vulnerability.

To counter and sanction this phenomenon, and to restore and develop the U.S. position in this field, the U.S. is gradually implementing these measures. After a trial period with a $0 per net ton fee for arriving ships effective April 17, the $50 per net ton fee will take effect on October 14.

Impact Analysis：

It is noteworthy that the varying fee standards outlined in the annex, while not uniform, all specifically target China's maritime, logistics, and shipbuilding industries. The broader impact ultimately extends to international logistics and trade businesses, including cross-border e-commerce. The imposition of fees will lead shipping companies to pass the costs on to shippers per container, resulting in increased costs. This, in turn, will raise commodity prices, potentially reducing sales volumes. Ultimately, local consumers will bear the cost, and sustained price increases could lead to inflation, causing multifaceted effects and changes.

Reactions from Various Parties：

China's Ministry of Commerce has expressed "strong dissatisfaction and firm opposition," accusing the U.S. of "clear discrimination and seriously disrupting global industrial and supply chain stability." The global shipping industry has expressed strong dissatisfaction, with particularly strong opposition from Southeast Asian and African countries, as they largely rely on Chinese-built ships. Even the American Shipowners Association has publicly opposed the move, for the fear that will cause chaos in global supply chains. A July 9 report by The Wall Street Journal mentioned that 80% of the cranes at U.S. East Coast ports are still maintained by Chinese companies. Port and terminal operating companies are concerned that these tariffs will impose additional costs on ports that ordered cranes long before the new policy was proposed, and that the severe shortage of manufacturers outside China has not been taken into account.

Till present, no specific countermeasures have been announced. Some businesses, to preemptively address this trade change, have already planned to stock up on goods in the U.S. locally before the policy is formally implemented, allowing sufficient time for countermeasures to be developed.