USTR Proposes Pausing China Ship Fees Until Jan 9, 2027. The 178 Exclusions Are Not in the Proposal

October 30, 2026 · Updated November 2, 2026

Updated Nov 2, 2026: The comment period on USTR's proposal closed October 30. As of November 2, USTR has not published a final decision, and no notice extending the 178 exclusions has been published or placed on public inspection. Seven days remain until 11:59 p.m. Eastern on November 9.

China Ship Fee Pause to Jan 9, 2027 Is Still Not Final. The 178 Exclusions End in 7 Days.

Seven days to the Nov 9 deadline. USTR has not finalized the ship fee pause, and nothing extends the 178 Section 301 exclusions.

Comments on USTR's proposal to keep the China ship fees paused through January 9, 2027, closed on Friday, October 30. As of Monday, November 2, USTR has not published a final decision in the Federal Register, and we found none on the Federal Register's public inspection list.

The 178 China Section 301 product exclusions are a separate matter. They were never part of the proposal, and no notice extends them. Unless that changes, they end at 11:59 p.m. Eastern on Monday, November 9, seven days from today.

For background, see our earlier pieces: Two China Tariff Deadlines Expire Nov 9 and China Section 301 Exclusions End Nov. 9.

Check if your product is one of the 178: see the full list, with every HTS code. Shipping from China this week? Get a freight quote.

Key facts

• Notice: Request for Comments on Further Suspension of Section 301 Action: China's Targeting of the Maritime, Logistics, and Shipbuilding Sectors for Dominance

• Federal Register: FR Doc. 2026-21755, published October 26, 2026

• Status as of Nov 2: Proposed. Comments closed October 30, 5:00 p.m. ET. No final notice published.

• Docket: USTR-2026-0694, on comments.ustr.gov

• Proposed new pause: 12:00 a.m. ET, November 10, 2026, through 11:59 p.m. ET, January 9, 2027

• What it covers: Fees on maritime transport services (Annexes I, II and III of USTR's April 23, 2025 notice, as modified October 16, 2025) and the duties in Annex V.A of the October 16, 2025 notice

• What it does not cover: The 178 China Section 301 product exclusions

• Exclusion headings: 9903.88.69 and 9903.88.70

• Current pause and exclusions end: 11:59 p.m. ET, November 9, 2026

• Days left: 7

Key dates

What changed since Oct 30

Very little on paper, and that is the news.

• The comment period on the maritime proposal closed at 5:00 p.m. Eastern on October 30.

• As of November 2, USTR has not published a final decision on FR 2026-21755.

• No USTR document appears on the Federal Register's public inspection list, where notices usually show up a day or more before they are published.

• No USTR press release since October 26 addresses the ship fees or the 178 exclusions.

• No notice extends the 178 exclusions.

The proposal itself has not changed. It would suspend the maritime action from 12:00 a.m. Eastern on November 10, 2026, through 11:59 p.m. Eastern on January 9, 2027. During that time, the notice says, no party would accrue liability for or be required to pay the maritime service fees or the Annex V.A duties.

What is proposed and what is final

Proposed, still pending: the two-month extension of the maritime pause to January 9, 2027. Comments are closed. USTR has not said what it decided.

Final: the current pause, which ends at 11:59 p.m. Eastern on November 9, 2026, under the November 13, 2025 notice.

Final, with no proposal to change it: the 178 exclusions under headings 9903.88.69 and 9903.88.70, which end at 11:59 p.m. Eastern on November 9, 2026, under the December 1, 2025 notice.

Last year, USTR proposed the one-year suspension on November 6, 2025, and published the final suspension on November 13, 2025, three days after it took effect. A final notice this year could also arrive close to, or after, November 10. Until it is published, the proposal is not law.

What it means for duty

For most importers, the maritime proposal does not change the duty bill. The ship fees are charged to vessel operators. If you import goods covered by the Annex V.A duties in USTR's October 16, 2025 notice, review your entries with your broker.

The 178 exclusions are the real duty risk this week. If your product uses one and no extension is published, the China Section 301 duty applies to goods entered for consumption or withdrawn from warehouse after 11:59 p.m. Eastern on November 9. The entry date decides it, not the purchase order or the sailing date.

To check your exposure:

1. Look up your product in the 178 exclusions list. 26 of the exclusions cover a whole statistical line. The other 152 cover only the product their written description names.

2. Confirm your 10 digit code with the HTS code lookup, which searches the 2026 USITC schedule and shows the duty.

3. For which list your code sits on and the rate that applies, see our complete guide to Section 301 China tariffs in 2026.

If you file under an exclusion whose HTS code changed on July 1, 2026, CBP's CSMS #70261629 (October 22, 2026) explains how to enter the conforming amendments. As of November 2, we have not found a CBP message on what happens to entries after November 9.

What it means for freight

If the ship fees return on November 10, carriers are charged and are likely to pass the cost through as surcharges. If USTR finalizes the extension, that risk moves to January 9, 2027.

Cargo sailing from China this week will not arrive before November 9. Transpacific transit from the main Chinese gateways usually takes several weeks. For goods that rely on an exclusion, plan landed cost as if the exclusion has ended, unless a notice says otherwise. Check conditions by port:

• Shanghai: live vessels and congestion on the Port of Shanghai (CNSHG) page.

• Ningbo: the Port of Ningbo (CNNGB) page.

• Shenzhen: the Port of Shenzhen (CNSHK) page.

For cargo already on the water, ask your forwarder for a realistic arrival and entry date, not just an ETA at the port.

What to check this week

• Every HTS code you import from China: check it against the 178 exclusions list.

• Cargo in transit: for each shipment using an exclusion, confirm whether entry will happen before or after 11:59 p.m. Eastern on November 9.

• Entries this week: if goods are already in the U.S., ask your broker whether entry can be filed before the deadline.

• Freight contracts: ask your carrier or forwarder how a ship fee surcharge would be passed through from November 10 if the pause is not finalized.

• Landed cost: reprice affected SKUs without the exclusion, so a November 10 change does not hit your margins unplanned.

• Alerts: follow the Tariff Radar, which logs each U.S. tariff change with its Federal Register or CBP source and sends free email alerts when a rate changes.

What could change before Nov 9

• USTR finalizes the maritime extension. The pause would run through 11:59 p.m. Eastern on January 9, 2027.

• USTR finalizes something different. The final notice could differ from the proposal.

• USTR publishes late. Last year's final suspension came three days after the effective date. A notice could arrive after November 10.

• USTR publishes a separate notice on the exclusions. As of November 2, none has been published or filed for public inspection. Without one, all 178 expire on November 9.

• CBP issues guidance. CBP usually issues a CSMS message telling filers how to apply a change.

We will update this page when any of these happens.

Frequently asked questions

Has USTR delayed the China ship fees to January 9, 2027?

Not yet. USTR proposed it on October 26, 2026, in FR Doc. 2026-21755. Comments closed October 30. As of November 2, USTR has not published a final decision.

Are the 178 China Section 301 exclusions extended?

No. As of November 2, 2026, no notice extends them. They end at 11:59 p.m. Eastern on November 9, 2026.

Can I still comment on the proposal?

No. The comment period under docket USTR-2026-0694 closed at 5:00 p.m. Eastern on October 30, 2026. You can still view public submissions on comments.ustr.gov.

When would the extended pause start and end?

From 12:00 a.m. Eastern on November 10, 2026, through 11:59 p.m. Eastern on January 9, 2027, if finalized as proposed.

Do importers pay the China ship fees?

The fees are charged on maritime transport services, so carriers pay them. Importers usually feel them as surcharges on the freight bill.

How do I know if my product uses one of the 178 exclusions?

Search your HTS code or product in the China Section 301 exclusions list. For 152 of the 178, the HTS code alone is not enough: your product must match the written description.

Does shipping before November 9 protect my goods?

No. Duty is based on when goods are entered for consumption or withdrawn from warehouse, not when they sail.

Sources

• USTR, Request for Comments on Further Suspension of Section 301 Action (maritime), FR Doc. 2026-21755, October 26, 2026

• USTR, Notice of Modification of Section 301 Action (maritime suspension), FR Doc. 2025-19873, 90 FR 50947, November 13, 2025

• USTR, Notice of Action and Proposed Action (maritime), FR Doc. 2025-06927, 90 FR 17114, April 23, 2025

• USTR, Notice of Product Exclusion Extensions (178 exclusions), FR Doc. 2025-21671, 90 FR 55232, December 1, 2025

• USTR, Continuation of Actions (China Section 301), FR Doc. 2026-20510, 91 FR 64212, October 7, 2026

• USTR, Notice of Conforming Amendment to Product Exclusion, FR Doc. 2026-20511, 91 FR 64211, October 7, 2026

• CBP, CSMS #70261629, Updated Guidance: Section 301 China Conforming Amendment, October 2026

• Federal Register public inspection and document search, checked November 2, 2026

Calculate Your Import Duties

Find your HTS code, check whether it is on the 178 exclusions list, and see the duty that applies after November 9. Calculate your import duties.

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