In light of the Notice of Action and Proposed Actions issued under the United States Trade Representative’s (USTR) Section 301 investigation into China’s targeting of the maritime, logistics, and shipbuilding sectors, BIMCO has received inquiries regarding potential implications for ship management agreements – particularly SHIPMAN – and whether additional contractual measures may be needed. The Section 301 Proposed Actions set out potential trade restrictions and increased regulatory scrutiny focused on Chinese entities and interests in the maritime domain. These developments have understandably raised concerns among shipowners, charterers, and managers – particularly in cases where corporate structures involve Chinese interests. BIMCO Response: Time Charter Clause issued, no SHIPMAN Clause planned As part of its response, BIMCO has developed a USTR Clause for Time Charter Parties, which is intended to help allocate roles and responsibilities between owners and charterers in light of these developments. At this stage, and drawing on input from the industry, BIMCO does not plan to develop a SHIPMAN clause specifically addressing the USTR’s Proposed Actions. The concerns raised appear to centre more on regulatory filings and operational procedures than on contractual relationships between owners and managers. All parties – owners, charterers, and managers – share a common interest in reducing risk and avoiding unintended regulatory exposure. To mitigate such exposure, the parties can address this through close cooperation and clear communication when completing filings, particularly with respect to identifying the vessel operator. Key Issue: COFR Registration and Form 1300 (Box 9) The Proposed Actions targets the vessel operator, and states that that the vessel operator is the entity identified as the owner of vessel and whose name appears on the Vessel Entrance of Clearance Statement (CBP Form 1300) or its electronic equivalent. In turn, Block 9 of CPB Form 1300 ide