On April 17, 2025, the Office of the U.S. Trade Representative (USTR) announced targeted actions “to restore American shipbuilding” after its determination that China was implementing “unreasonable acts, policies, and practices to dominate the maritime, logistics, and shipbuilding sectors.” Although the specific details of the targeted actions differ from USTR’s proposed actions (see Update of February 26, 2025), the targeted actions remain largely consistent with the USTR’s proposals. Unlike the proposals, however, the targeted actions propose additional duties on Ship-to-Shore (STS) cranes and cargo handling equipment from China.

According to the Federal Register notice, certain Chinese vessels will soon incur a service fee that increases over five phases:


Phase
Service Fee on
Vessel Operators and Vessel Owners of China
(see Annex I)
Service Fee on
Vessel Operators of Chinese-Built Vessels
(see Annex II)
Phase I
(April 17–Oct. 13, 2025)

$0
Either $0 per net ton for the arriving vessel or $0 for each container discharged
Phase II
(Oct. 14, 2025–April 16, 2026)
$50 per net ton for the arriving vesselEither $18 per net ton for the arriving vessel or $120 for each container discharged
Phase III
(April 17, 2026–April 16, 2027)
$80 per net ton for the arriving vesselEither $23 per net ton for the arriving vessel or $153 for each container discharged
Phase IV
(April 17, 2027–April 16, 2028)
$110 per net ton for the arriving vesselEither $28 per net ton for the arriving vessel or $195 for each container discharged
Phase V
(April 17, 2028–onwards)
$140 per net ton for the arriving vesselEither $33 per net ton for the arriving vessel or $250 for each container discharged

To promote U.S.-built vessels, the Federal Register notice includes a new “Service Fee on Vessel Operators of Foreign-Built Vehicle Carriers” (see Annex III). Like the service fees on Chinese vessels, this service fee does not take effect until October 14, 2025, when a fee of $150 per Car Equivalent Unit (CEU) capacity will be assessed on each entering non-U.S.-built vessel.

To “promote the transport of U.S. goods on U.S. vessels,” the USTR will also require that a certain percentage of liquified natural gas (LNG) exports to the United States be transported exclusively on U.S. vessels, but this requirement does not begin until April 17, 2028 (see Annex IV). The requirement starts at 1% but gradually increases to 15% by April 17, 2047.

Request for Public Comments on Proposed Additional Duties

Consistent with Executive Order 14269 of April 9, 2025 (“Restoring America’s Maritime Dominance”), the Federal Register notice proposes additional duties on STS cranes and cargo handling equipment of China to 100% (see Annex V). For all these proposed tariff actions, the USTR is requesting public comments from interested parties. Any comments must be submitted no later than May 19, 2025, via the USTR’s electronic portal: https://comments.ustr.gov/s/. The docket number for written comments is USTR–2025–0008.

On May 19, 2025—the same day public comments are due—the USTR will hold a public hearing on the proposed tariff actions in the main hearing room of the U.S. International Trade Commission. Any request to appear at this hearing must be submitted no later than May 8, 2025, via the same USTR portal under docket number USTR–2025–0009. Requests to appear must include a summary of testimony and may be accompanied by a pre-hearing submission. Remarks at the hearing are limited to five minutes.

Background of the Section 301 Investigation

The USTR’s targeted actions follow a year-long Section 301 investigation that concluded China’s behavior was “actionable” (see Update of January 17, 2025). Section 301 allows the United States to respond to unreasonable or discriminatory foreign government practices that burden or restrict U.S. commerce. For additional background on the Section 301 investigation, see Bulletin of April 23, 2024 and Update of April 17, 2024 (detailing the initiation of the Section 301 investigation), and Update of March 13, 2024 (detailing the petition filed requesting the Section 301 investigation).

Photo of Aaron C. Mandelbaum Aaron C. Mandelbaum

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade…

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.

Photo of David M. Schwartz David M. Schwartz

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping…

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping (AD), countervailing duty (CVD) and safeguard litigation, international trade policy, and cross-border compliance issues affecting goods, services, technology and investments that involve transportation, customs, export controls, economic sanctions, anti-boycott and anti-bribery laws and regulations.

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

Photo of Dan Ujczo Dan Ujczo

Dan focuses his practice on providing end-to-end counsel across clients’ Canada-United States, North American and global supply chains. This trade counsel includes customs classification and compliance, utilization of preferential trade agreements such as the USMCA, tariff mitigation and exclusions, procurement issues such as…

Dan focuses his practice on providing end-to-end counsel across clients’ Canada-United States, North American and global supply chains. This trade counsel includes customs classification and compliance, utilization of preferential trade agreements such as the USMCA, tariff mitigation and exclusions, procurement issues such as Buy America/Buy American, and anti-dumping/countervailing duty issues. He also advises clients on negotiating transportation agreements, managing trusted trader and related security programs, and addressing issues at ports-of-entry.