These fees are assessed against the operator listed on the vessel’s COFR — a fact with far-reaching implications for shipowners, managers, and charterers.

In our latest Client Advisory and Podcast (Episode 41), we explain:

  • Who’s now liable for these fees
  • The risks of a cosmetic “operator” name change
  • Contractual and operational steps to take immediately
  • New guidance from CBP, USTR, and legal commentators
  • What to watch for from Beijing in response