The New York New Jersey Foreign Freight Forwarders and Brokers Association, Inc. (NYNJFF&BA) has submitted formal comments opposing proposed trade actions by the Office of the United States Trade Representative (USTR) under Section 301, which targets China’s dominance in maritime, logistics, and shipbuilding sectors.
The Association strongly warns that the proposed service fees on maritime operators using Chinese-built ships—as well as a requirement for U.S. exports to be transported on U.S.-flagged vessels—would severely damage the supply chain, reduce competitiveness, increase costs for U.S. exporters and consumers, and ultimately weaken the very industries the policy seeks to protect.
The NYNJFF&BA represents over 145 freight forwarders and customs brokers, handling cargo nationwide. While acknowledging the long-term strategic advantages China has built in shipbuilding, the Association stresses that penalizing current operators will not change past investment decisions nor reverse China’s market lead. Instead, it urges the U.S. government to focus on long-term solutions, including the “Ships for America Act,” to rebuild domestic shipbuilding and maritime capabilities.
They recommend a market-driven alternative to mandates, suggesting export tax credits for shipments on U.S.-built and U.S.-flagged vessels, which could incentivize growth in domestic maritime capacity without causing immediate disruption.
Key Concerns Raised by NYNJFF&BA:
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Congestion & Delays: Port calls would be reduced, especially at smaller ports, worsening congestion at major hubs like the Port of NY/NJ.
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Cost Escalation: Carriers may pass new fees onto exporters/importers, driving up prices.
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Reduced Competition: Smaller carriers would exit the market, harming service diversity and supply chain resilience.
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Unintended Consequences: Redirecting cargo through Canada or Mexico could cause delays and increase intermodal costs.
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Ineffectiveness of Fees: Chinese dominance stems from long-term industrial strategy; short-term penalties will not reverse this.
Conclusion: The Association urges the USTR to reconsider the proposed fees and mandates, advocating instead for structural reforms, financial incentives, and long-term investment in U.S. maritime infrastructure. They argue the proposed measures would inflict economic harm while failing to curb Chinese influence in the industry.
