CBP ISSUES UPDATED GUIDANCE ON SECTION 301 FOREIGN-BUILT VESSEL FEES

U.S. Customs and Border Protection (CBP) recently released updated guidance following the October 14, 2025, effective date of the Section 301 vessel fees for foreign-built ships. The update clarifies payment procedures, exemptions, and operator responsibilities consistent with the Federal Register notice, “Notice of Action and Proposed Action in Section 301 Investigation of China’s Targeting the Maritime, Logistics, and Shipbuilding Sectors for Dominance,” published on April 17, 2025, and modified on June 12, 2025.

WHAT FEES APPLY UNDER EACH SECTION 301 ANNEX?

Effective October 14, 2025, vessel operators must pay the applicable fee on or before the vessel’s entry at the first U.S. port or place from outside the customs territory. CBP confirmed that the obligation to determine whether a vessel owes a fee lies entirely with the operator, not with CBP.

The following rates now apply:

• Annex I – Chinese Vessel Operators and Vessel Owners: $50 per net ton for arriving vessels owned or operated by a Chinese entity.
• Annex II – Chinese-Built Vessels: The higher of $18 per net ton or $120 for each container discharged from an arriving Chinese-built vessel.
• Annex III – Foreign-Built Vehicle Carrier Vessels: $46 per net ton for vehicle carriers and roll-on/roll-off vessels built outside the United States.

Liquefied Natural Gas (LNG) tankers, designated as vessel type 132 by the International Classification of Ships by Type (ICST), are exempt from all three Annexes.

WHEN AND HOW MUST FOREIGN-BUILT VESSEL FEES BE PAID?

Fees must be paid through the Department of the Treasury’s secure payment portal, Pay.gov, not at the Port of Entry. The website automatically calculates total fees based on the selected Annex type and data entered in the Section 301 Fee Payment Form. Payment confirmations are transmitted to the Vessel Entrance and Clearance System (VECS).

If VECS cannot match a payment to an arriving vessel, operators or filers may provide proof of payment using the confirmation email issued by Pay.gov. CBP recommends initiating payment at least three business days before vessel arrival to ensure verification prior to entry.

WHAT INFORMATION IS REQUIRED IN THE SECTION 301 FEE PAYMENT FORM?

The Section 301 Fee Payment Form on Pay.gov prompts responsible parties to provide vessel and voyage details before selecting the applicable Annex.

Required fields include:

• Vessel name, arrival port, and estimated arrival date
• IMO or official number and voyage number
• Vessel operator name, tax ID or CBP number
• Payor name, address, and contact information
• Form of payment (ACH debit)

After this information is entered, the filer selects Annex I, Annex II, or Annex III and inputs the required information for net tonnage or container count.

WHAT ARE THE OPERATIONAL RESPONSIBILITIES FOR FOREIGN-BUILT VESSEL OPERATORS?

CBP emphasized that the operator bears full responsibility for determining applicability, paying required fees, and maintaining proof of payment prior to vessel arrival. Vessels without verified payment may be denied lading or unlading operations or have clearance withheld until proof of payment is confirmed.

Operators using VECS will see the relevant details within their filings and must verify or update information as needed. Those filing via paper must complete and review their submissions manually for compliance with Annex requirements.