USTR Fees Task Force

Our team is well positioned to advise shipowners, operators and ship managers on all aspects of U.S. Trade Representative (USTR) fees affecting Chinese-linked vessels.

The USTR in April 2025 issued a Notice of Action and Proposed Action in Section 301 Investigation of China's Targeting the Maritime, Logistics, and Shipbuilding Sectors for Dominance, with modifications published on June 12, 2025, and Oct. 10, 2025. That Notice of Action implemented service fees targeting vessels linked to China as part of broader trade measures aimed at addressing concerns over unfair trade practices and national security risks. Maritime stakeholders should be prepared to begin paying the fee increases, which took effect on Oct. 14, 2025. These fees will generally apply upon entry to U.S. ports to vessels that are owned or operated by Chinese entities and operators of Chinese-built vessels.

Holland & Knight's USTR Fees Task Force is distinctly positioned to guide shipowners, operators and ship managers through the complex landscape of USTR fees imposed on Chinese-linked vessels. Our team brings together a rare blend of deep maritime industry knowledge and direct experience in U.S. trade enforcement, including former professionals from the USTR office, U.S. Customs and Border Protection (CBP) and U.S. Coast Guard.

Extensive Experience in Trade and Maritime Law

Our Task Force members have advised a wide range of international shipping clients on the implications of USTR fees, providing tailored solutions that address the operational, financial and compliance challenges presented by these regulations. Our hands-on experience includes detailed assessments of vessel ownership structures, cargo origination and routing strategies to minimize exposure and help ensure full regulatory compliance.

Deep USTR and CBP Knowledge

Our team's former USTR and CBP officials provide clients an inside perspective on regulatory intent, enforcement priorities and practical compliance strategies. This substantial knowledge and experience gives our attorneys and policy professionals the ability to anticipate regulatory shifts and advocate effectively on behalf of our clients in discussions with federal agencies.

Navigating the Intersection of Trade and Maritime Risk

The issues presented by USTR fees on Chinese-linked vessels often merge trade and maritime risk in unprecedented ways. Our Task Force is adept at managing these complexities, advising on matters such as:

• assessing vessel exposure to USTR fees based on ownership, operator status, charter arrangements and trade routes, including fees in China on U.S.-owned, -flagged, -built and -operated vessels
• developing compliance programs that address both trade and maritime regulatory requirements
• mitigating the risk of enforcement actions, fines and operational disruptions
• assisting with voluntary disclosures and responses to government inquiries

Strategic Solutions for a Changing Regulatory Environment

As the regulatory landscape evolves, our USTR Fees Task Force remains at the forefront, engaging with clients and helping them navigate uncertainty and maintain business continuity. Our lawyers and professionals provide proactive risk assessments, tailored compliance strategies and ongoing monitoring of trade and maritime developments that may impact our clients' operations.

With our distinct combination of industry insight and government experience, Holland & Knight is a trusted advisor for shipowners, operators and ship managers confronting the challenges of USTR fees on Chinese-linked vessels.