Industry insiders suggest that "when soldiers come, generals will block; when water comes, earth will cover," indicating that the actual situation may not be worse than anticipated.

"Currently, our orders are scheduled until 2029. Orders mainly come from Asia and Europe, with zero orders from the United States," a representative from Shanghai Waigaoqiao Shipbuilding told reporters. The US is not primarily a shipowner-concentrated country, but recent US measures restrict not only Chinese-built vessels but also place Chinese-owned or operated ships at the forefront. "The main restrictions target ships operating US routes, regardless of shipowner nationality, involving shipowner route deployment and other complex and sensitive issues."

Recently, the US Customs and Border Protection (CBP) officially issued the "Section 301 Vessel Fees" announcement, declaring that starting October 14th, new port service fees will be imposed on Chinese-owned, operated, or built vessels, as well as foreign-built vehicle carriers entering US ports.

Luo Wen (pseudonym), an industry insider in China's shipping supply chain, stated that this will first impact the operating costs of Chinese shipping companies and shipowners, followed by shipyards, and then ship-related equipment and component supply chains. However, "when soldiers come, generals will block; when water comes, earth will cover," and the actual situation will not be worse than anticipated.

The State Council implemented the newly revised "International Maritime Transport Regulations" on September 29th, which includes new countermeasure clauses, explicitly allowing for reciprocal fees, port restrictions, and other countermeasures against countries implementing discriminatory measures.

Impact on Shipping Company Costs and Freight Rates

"If strictly enforced, the impact will inevitably be significant," said Chen Yang, head of Maritime Network, a professional shipping information consulting platform. Chinese shipping companies and shipping investment bank-invested leasing companies will first face direct impacts such as rising costs. From a purely commercial cost perspective, some international shipping companies might even relocate their headquarters from Hong Kong, Macau, and other locations, while inevitably causing some foreign shipowners to reconsider placing new orders at Chinese shipyards.

According to the CBP announcement and its attachments (CSMS Attachment), the fee structure is divided into three categories: First, Chinese-owned or operated vessels face an initial rate of $50 per net ton; second, Chinese-built vessels are charged $18 per net ton or $120 per container, whichever is higher, with rates increasing annually; third, vehicle carriers or roll-on/roll-off ships face $14 per net ton. The announcement clarifies that vessel operators are responsible for payment and must complete declaration and payment before entering port, or face administrative penalties.

Shipping consultancy Alphaliner estimated in late September that this US measure would add $3.2 billion in costs for the world's top ten container shipping companies in 2026. COSCO and OOCL would collectively bear $1.53 billion, accounting for nearly 50%; ZIM Integrated Shipping Services Ltd., ONE, CMA CGM, MSC, and Hapag-Lloyd would respectively increase expenditures by $510 million, $363 million, $335 million, $244 million, and $105 million.

Due to fewer Chinese-owned and built vessels, Maersk's fleet would "only" need to pay $17.5 million in fees. Evergreen Marine and HMM fleets mainly consist of Korean-built vessels, thus requiring no additional port fees. It should be noted that the fees calculated at that time were generally slightly higher than currently published fees, with some detail differences, but the impact and variations among companies are evident.

According to HKTDC Research data, approximately 13% of Chinese ocean-going vessels docked at US ports in 2024. Calculated by net tonnage, additional costs would increase freight rates by 5% to 8% on some routes. Meanwhile, affected by US government "shutdown" and reduced customs personnel, port efficiency has already declined significantly, and implementing new fee rates may further disrupt cargo flow.

Regarding international freight rates, combined with currently weak freight demand fundamentals, multiple shipping companies have indicated they will not raise prices due to increased port fees, mainly absorbing costs through optimized deployment and other methods.

Global freight forwarding giant Kuehne + Nagel previously announced that the number of affected container ships is far lower than initially expected in the draft, allowing most shipping companies to flexibly adjust fleet deployment by withdrawing Chinese-flagged vessels to avoid additional US port fees. COSCO faces significantly higher fee risks than other shipping companies, with greater difficulty in avoidance and obvious pressure on US route operations. Simultaneously, some shipping companies have explicitly stated they will not impose port fee-related charges on cargo bound for the United States to maintain customer confidence and market stability.

Wang Zhicong, Market Director at Shenzhen Baosen Santong Logistics Co., Ltd., reported that inquiries with shipowners and several peer companies have yielded no information about price increases due to port fees.

Will Global Shipping Patterns Be Reshaped?

Focusing on the shipbuilding industry, China continues to lead globally in three major indicators: shipbuilding completions, new order intake, and order backlog market share. Many leading Chinese shipbuilders currently have orders scheduled beyond 2029.

According to data from authoritative institution Clarkson Research, China currently holds over 40% of the global shipbuilding market share, far exceeding South Korea and Japan, while the US shipbuilding industry accounts for less than 1% of the global market.

This means that rather than restoring its own supply chain, the US intent appears more focused on "suppressing" China while "elevating" Japan and South Korea. Overall, global shipbuilding presents a "tripod" situation among China, Japan, and South Korea, and US measures targeting Chinese-built and owned vessels somewhat benefit Japanese and Korean shipyards.

Facing Chinese shipyards' busy schedules extending four years ahead, Luo Wen noted that within shipping companies, order backlog is not the most important assessment indicator; new order intake is more critical. "Shipbuilding and major equipment involve significant value, and after contract signing, contract effectiveness payments are involved. Even 10%-20% represents substantial fees, meaning orders placed are unlikely to be easily changed or cancelled."

However, Luo Wen also believes the industry has concerns about new order growth momentum. After years of rapid growth, inquiries for ships and components have decreased since this year. Certainly, the decrease is also related to the industry's own cycles. China's strong supply chain foundation and new energy advantages remain enormous, and its dominant position in shipbuilding and port infrastructure is difficult to overturn. Therefore, regardless of future policy changes between China and the US, final developments may not be as worrisome as the industry fears.

Ju Jiandong, Ziguang Chair Professor at Tsinghua University's PBC School of Finance, proposed that the US unilaterally raising tariff barriers will significantly increase global trade costs, creating high uncertainty in global trade policy, damaging not only global trade but also US trade. In global foreign trade port throughput, China accounts for approximately 41%, the US about 6%, and other world regions about 53%. In global goods trade, China's world share exceeds the US in most industries, so the US loses out in trade wars in most goods trade industries. In shipping industry trade wars, the US also loses out.

Chen Yang also believes such US policies are unpopular and difficult to sustain long-term, and China can continue winning in both shipbuilding and shipping through efficiency, technology investment, and strong supply chains.

China's Countermeasures and Response

"China's response adopts strategically equivalent but tactically asymmetric approaches," said a lawyer experienced in international trade disputes. On one hand, China maintains its customary "reactive" stance, with the newly revised "International Maritime Transport Regulations" explicitly allowing countermeasures against discriminatory actions according to law. On the other hand, while strategically equivalent, specific tactics need not be equivalent. "It's not necessarily 'you collect money, I collect money too,' but could include restricting corresponding data and information provision."

The revised "International Maritime Transport Regulations" released and implemented on September 29th changed Article 46 to Article 48, stating: Countries or regions that have concluded or jointly participated in international maritime-related treaties and agreements with the People's Republic of China, if they violate treaty or agreement provisions, causing loss or damage to benefits China enjoys under such treaties or agreements, or hindering treaty or agreement objective achievement, the Chinese government has the right to demand relevant countries or regional governments terminate such actions, adopt appropriate remedial measures, and may suspend or terminate fulfilling related obligations according to relevant treaties or agreements.

Simultaneously, according to actual circumstances, necessary countermeasures may be adopted, including but not limited to: charging special fees to vessels from such countries or regions berthing at Chinese ports; prohibiting or restricting vessels from such countries or regions from entering or exiting Chinese ports; prohibiting or restricting organizations and individuals from such countries or regions from obtaining China's international maritime transport-related data and information, and operating international maritime transport and auxiliary services in and out of Chinese ports.

The Ministry of Commerce stated it will unite with the EU, Japan, South Korea, and other shipping stakeholders to initiate compliance litigation within the WTO framework, questioning the discriminatory nature of US measures. The China Shipowners' Association is promoting establishment of an "International Shipping Fairness Alliance," uniting over 20 major global shipowners to jointly resist unilateral trade restrictions.

According to the lawyer's observations, whether previous US investigations or current announced measures possess both political and economic characteristics, with political considerations often outweighing economic ones. Changes visible from initial suggestions to final implementation show that excessive political considerations don't fully match US economic objectives. Therefore, final measure rollouts must consider more of their own economic interests, such as explicitly exempting liquefied natural gas (LNG) transport vessels and implementing progressive fees to avoid backlash effects from political actions.

This also means sustainability, implementation, and enforcement of related measures still face variables and uncertainties.

Strategically, under China's "growing stronger through adversity" background and confidence, companies cannot avoid impacts and actual losses from uncertainty, with individual experiences varying. What can be done is accelerating capacity adjustments to reduce impacts from rising costs.

According to public reports, companies like COSCO have launched "fleet optimization plans," with 20 Chinese-built large container ships transferring to Asia-Europe routes while increasing leases of Korean-built vessels to operate US West Coast routes. Financially, multiple shipping companies plan to partially offset costs through General Rate Increases (GRI), with Shanghai-Los Angeles routes already showing $1,000 per container surcharge increases.

Industrially, the China Association of the National Shipbuilding Industry proposed a "dual-track development strategy," accelerating green vessel technology research while expanding "Belt and Road" markets. Similar to tariff war impacts, while Chinese exports to the US declined significantly, the gap was quickly filled by increases in non-US markets.