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

The ship fee pause may get two more months. The 178 Section 301 product exclusions still end at 11:59 p.m. Eastern on Nov 9, and nothing published so far changes that.

On October 26, 2026, the U.S. Trade Representative (USTR) published a proposal to keep the China maritime action suspended for two more months, through January 9, 2027. It is a proposal, not a final decision. Comments close today, October 30, at 5:00 p.m. Eastern.

That changes part of what we wrote earlier this month in Two China Tariff Deadlines Expire Nov 9. The two deadlines are no longer on the same track. The ship fee pause has a proposed extension. The 178 exclusions do not.

Check if your product is one of the 178: see the full list, with every HTS code. Shipping from China before Nov 9? 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: Proposed. Not final.

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

• What it covers: The 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

• Comment deadline: October 30, 2026, 5:00 p.m. ET

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

• Current pause ends: 11:59 p.m. ET, November 9, 2026, unless USTR finalizes the extension

Key dates

As of October 30, 2026, USTR has not finalized the proposed extension, and we found no Federal Register notice extending the 178 exclusions.

What changed

Until last week, both China deadlines pointed at the same night: 11:59 p.m. Eastern on November 9, 2026. Our October 6 piece on the 178 exclusions and our October 13 piece both said no notice had moved either date.

USTR has now moved, on paper, for one of them. The notice says the United States "is continuing to engage with China" and proposes to "further suspend for two months, through January 9, 2027" the actions in the maritime, logistics and shipbuilding investigation. During that period, the notice says, no party would accrue liability for or be required to pay the maritime service fees or the Annex V.A duties.

The notice says nothing about the product exclusions in the separate China Section 301 investigation on technology transfer and intellectual property. Those are the 178 exclusions. They come from a different investigation, under a different notice, with their own expiry.

What is proposed and what is final

Proposed: the two-month extension of the maritime pause to January 9, 2027. USTR asked for comments and set a deadline. It has not said what it decided.

Final: the current pause, which runs through 11:59 p.m. Eastern on November 9, 2026. That end date was set in the November 13, 2025 notice and is still the date in force.

Final, with no proposal to change it: the extension of the 178 exclusions to 11:59 p.m. Eastern on November 9, 2026, set in the December 1, 2025 notice.

Last year USTR followed the same pattern. It proposed the one-year suspension on November 6, 2025, and published the final suspension on November 13, 2025, after taking comments. A final notice this year could come before November 10, but until it is published, the proposal is not law.

What it means for duty

For most importers, this proposal does not change the duty bill.

The ship fees are charged to vessel operators, not importers. The proposal does also cover the Annex V.A duties from USTR's October 16, 2025 notice, so if you import goods covered by Annex V.A, check the proposal against your entries with your broker.

The 178 exclusions are the bigger duty risk. If your product uses one of them 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. What matters is the entry date, not the purchase order or sailing date.

To check your exposure:

1. Look up your product in the 178 exclusions list. It shows each exclusion with its HTS codes. 26 of them 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 the full picture of which list your code sits on and the rate that applies, see our complete guide to Section 301 China tariffs in 2026.

What it means for freight

If the ship fees come back, carriers are charged, and they are likely to pass the cost through as surcharges on the freight bill. If USTR finalizes the extension, that risk moves to January 9, 2027, and comes back into view right after the holiday season.

Either way, cargo leaving China now is close to the Nov 9 line. Transpacific transit from the main Chinese gateways usually takes several weeks, so cargo sailing today is already near or past the deadline. Here is what to look at by port:

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

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

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

If your goods rely on one of the 178 exclusions, the sailing date does not protect you. The entry date does. Ask your forwarder for a realistic arrival and entry date, not just a departure date.

What to check this week

• Today: if you want to comment on the maritime proposal, the deadline is 5:00 p.m. Eastern, October 30, under docket USTR-2026-0694.

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

• Cargo in transit: for any shipment using an exclusion, confirm whether it will be entered before or after 11:59 p.m. Eastern on November 9.

• Freight contracts: ask your carrier or forwarder how a ship fee surcharge would be passed through if the pause is not extended, and from what date.

• Landed cost: reprice affected SKUs with and without the exclusion, so a November 10 rate 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. A final notice would be published in the Federal Register.

• USTR changes the proposal. The final notice could differ from the proposal.

• USTR does nothing in time. The current pause would end at 11:59 p.m. Eastern on November 9.

• USTR publishes a separate notice on the exclusions. As of October 30, none has been published. Without one, all 178 expire on November 9.

• CBP guidance. CBP usually issues CSMS messages to tell filers how to apply a change like this. Watch for one before November 10.

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 has proposed it. The proposal was published October 26, 2026, as FR Doc. 2026-21755, and comments close October 30. As of October 30, USTR has not finalized it.

Are the 178 China Section 301 exclusions extended to January 9, 2027?

No. The proposal covers only the maritime action. As of October 30, 2026, the 178 exclusions still end at 11:59 p.m. Eastern on November 9, 2026.

When exactly 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 comment on the proposal?

Submit a written comment on comments.ustr.gov under docket USTR-2026-0694 by 5:00 p.m. Eastern, October 30, 2026. The notice says you do not need an account.

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?

Not for the exclusions. 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

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.

Get a freight quote

Moving cargo out of Shanghai, Ningbo or Shenzhen ahead of the deadline? Get a freight quote.