Skuld update guidance on the implementation of the China special port charges due to take effect on 14 October 2025

Background
Following Skuld article about Announcement 54, the Chinese Ministry of Transport has released the Implementation Measures regarding Special Port Charges for US vessels. Skuld thanks Wang Jing & Co for their guidance, including detailed instructions for completing the “Reporting Form of U.S.-Linked Vessel Information.” Members are encouraged to review their full article via the link below.
Brief highlights of the implementation measures
Vessels caught in any of the categories listed below must pay special port charges (See Skuld article 13 October 2025).
| Category Number | Ownership/Operation Category | Ownership/Operation Criteria | Exemptions |
| 1 | Owned by US enterprises, organisations, or individuals | Ownership | Vessels built in China |
| 2 | Operated by US enterprises, organisations, or individuals | Operation | Vessels built in China |
| 3 | Owned or operated by enterprises or organisations in which US enterprises, organisations, or individuals directly or indirectly hold 25% or more of the equity, voting rights, or board seats | Ownership/Operation with 25%+ equity, voting rights, or board seats | Vessels built in China |
| 4 | Flying the US flag | Flag | Vessels built in China |
| 5 | Built in the United States | Construction |
How will the special port charges be collected?
The maritime administration at the vessel’s port of call collects the Special Port Charges. For vessels visiting multiple Chinese ports on one voyage, charges are collected only at the first port; no additional charges apply at later ports.
What if a vessel makes six or more calls a year?
For vessels visiting Chinese ports over five times a year, Special Port Charges apply only to the first five calls; further visits are exempt upon proof of prior payment. No vessel is charged for more than five voyages per year, with the annual billing cycle beginning on 17 April 2026.
When is information to be submitted?
The owner or operator or their agent must at least seven days before arrival at a Chinese port — or upon departure if the voyage is under seven days — report to the maritime administration information on the vessel’s country of construction, flag state, owners, operators, leasing details, intended ports of call, via the “China International Trade Single Window” platform and pay the required Special Port Charges. For detailed reporting guidance please refer to the article by Wang Jing & Co. link attached.
What penalties apply if the information is incorrect?
At this stage, the penalties appear to be less severe than previously anticipated by Skuld. Skuld has been informed that if the information is not provided, the maritime authority will request the agent or owner/operator to correct or supply the relevant information.
What happens if payment is not made and the vessel leaves?
If Special Port Charges are not paid, vessel entry or clearance may be denied. If the vessel departs China without payment, it will be required to pay these charges on its next visit to China.
Will the special port charges apply to US nexus time and voyage charterers?
Currently, Special Port Charges do not appear to apply to voyage or time charterers. However, they are likely to apply to bareboat charterers. No specific guidance has been provided on this matter, and the situation may continue to develop in the coming weeks.
However, members are advised that this is a complicated area and that legal advice should be sought if members may fall into one of the categories, particularly category 3, or are a NVOCC and or ..’’ companies holding an International Ship Transport License under the Regulations on International Maritime Transport.”
Are there any exemptions to the special port charges?
Please refer to the table above. You will note that presently vessels built in China are exempted from category numbers 1-4, however we caution that this position may change and that the language of the Implementation Measures, generally, suggests flexibility should the Chinese Government wish to escalate matters. Additionally, unladen vessels entering Chinese shipyards solely for repairs, and other vessels that are recognised and approved for exemption, are also not required to pay. Wang Jing & Co. noted in their article that while ‘’other vessels that are recognised and approved for exemption’’ is not clearly defined, it may allow vessels needing emergency assistance or conducting humanitarian relief to request an exemption from the Maritime Authorities.
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