U.S. Fees on Chinese Built, Owned and Operated Vessels Guide for Members on Potential Legal Issues Last Updated 02 May 2025 Articles Ceri Done Published: April 11, 2025 Contact author Download article pdf This Guide has been prepared to assist Members in dealing with issues that might arise and on which Members might require Club assistance if the USTR’s recommendations are implemented.  What follows is a summary and this Guide will continue to be updated as matters develop. Advice in any given situation will depend heavily on individual circumstances and the terms of the applicable contract(s). Who is Targeted  On 17 April 2025, the United States Trade Representative (“USTR”) published a revised action plan in which it detailed revised plans to impose fees on (i) Chinese vessel operators and vessel owners (see Annex I); (ii) Operators of Chinese built vessels (see Annex II); and (iii) vessel operators of foreign vehicle carriers (see Annex III), with restrictions on LNG exports to follow (see Annex IV), as detailed in four Annexes. In response to concerns, the USTR’s plan does not include the previously proposed fee based on fleet composition.  Importantly, the revised action plan also now includes definitions of key terms and tests for determining if a vessel owner or operator is Chinese or if a vessel is “Chinese built” for the purposes of the plan, although some uncertainty remains: Annex I provides that the “vessel operator” and the “vessel owner” are the entities identified on the Vessel Entrance or Clearance Statement (U.S. Customs and Border Protection (CBP) Form 1300) as the operator and owner of the vessel respectively. However, Form 1300 does not expressly define these terms. Form 1300 defines “operator” by reference to the entity listed on the Certificate of Financial Responsibility (COFR) , which will likely be the vessel’s registered owner or a bareboat charterer. Form 1300 does not expressly define “owner” but this will likely be the ve