USTR Fees Task Force
Holland & Knight's USTR Fees Task Force helps shipowners, operators and ship managers navigate the evolving landscape of potential fees, taxes, tolls or similar measures that may affect vessels calling at U.S. ports.
The regulatory environment for vessels calling at U.S. ports remains dynamic. The U.S. Trade Representative (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 October 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 before being suspended for one year in November 2025.
Trade policy can shift quickly, and the current pause on the fees is set to expire in November 2026. As U.S.-China negotiations continue and the Trump Administration pursues policies to protect U.S. consumer market access and revitalize the domestic shipbuilding sector – a priority that will require significant funding mechanisms – new fees, taxes, tolls or similar measures on vessels could emerge at any time as potential revenue sources.
Industry-Leading Maritime and Trade Experience
Our USTR Fees Task Force combines deep maritime industry knowledge with direct experience in U.S. trade enforcement. We have advised a wide range of international shipping clients on USTR compliance measures, vessel ownership and operational structures, management approaches, documentation configuring, cargo origination and routing strategies to minimize exposure and ensure regulatory compliance.
Government Insiders on Your Side
Our USTR Fees Task Force includes former professionals from the USTR office, U.S. Customs and Border Protection (CBP) and U.S. Coast Guard (USCG). This inside perspective on regulatory intent and enforcement priorities allows us to anticipate shifts and advocate effectively on your behalf.
Potential fees, taxes, tolls or similar measures on vessels can create complex trade and maritime risks. Our USTR Fees Task Force advises on:
- comprehensive risk management
- vessel exposure assessments based on ownership, operator status, vessel management, charter arrangements and trade routes
- compliance programs addressing both trade and maritime regulatory requirements
- risk mitigation strategies for enforcement actions, fines and operational disruptions
- voluntary disclosures and responses to government inquiries
Stay Ahead of Regulatory Change
As trade negotiations continue, the regulatory landscape will keep evolving. Our USTR Fees Task Force provides proactive risk assessments, tailored compliance strategies and ongoing monitoring to help you maintain business continuity – no matter what comes next.
Contact our USTR Fees Task Force today to discuss how we can help protect your operations.
Primary Contacts
Sean Pribyl | Parter | Washington, D.C.
Patrick Childress | Partner | Washington, D.C.
