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U.S. federal maritime policy will shift meaningfully in the coming months and years following the Trump Administration’s announcement of the Maritime Action Plan (the MAP)<a href="#_ftn1" id="_ftnref1">[1]</a> on February&nbsp;16, 2026. The MAP is the Administration’s most comprehensive proposal to date for expanding U.S. shipbuilding capacity and repositioning the domestic maritime sector as a principal enabler of U.S. international trade and military capabilities.<a></a><a href="#_ftn2" id="_ftnref2">[2]</a>

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In the 1970s, U.S. shipyards were building roughly five per cent. of the world’s shipping tonnage, but that percentage has since dwindled and now lags significantly behind shipbuilding in the People’s Republic of China (the PRC) and certain other countries,<a href="#_ftn3" id="_ftnref3">[3]</a> and in the Administration’s view, these developments have made maritime capacity a U.S. national security issue, not just a commercial concern. The fact that the MAP was signed by acting National Security Advisor Marco Rubio, rather than the U.S. Secretary of Transportation, further highlights the Administration’s focus on national and economic security when revitalizing the maritime sector.

Speaking at CMA Shipping in March, U.S. Maritime Administrator Stephen M. Carmel emphasized that, although many discuss the MAP in terms of shipbuilding output, its ambitions extend far beyond shipyards alone. As he explained, the MAP is not a shipbuilding plan; it aims to rebuild the entire U.S. maritime ecosystem.<a></a><a href="#_ftn4" id="_ftnref4">[4]</a> As it stands presently, the United States is capable of building vessels over 400 feet long at only eight shipyards, and U.S. domestic shipbuilding is responsible for producing less than one per cent. of the world’s commercial fleet.<a href="#_ftn5" id="_ftnref5">[5]</a>

Critics of the MAP argue that national and economic security could be addressed by simply buying vessels from Asia and Northern Europe rather than trying to restart domestic shipbuilding over the next few decades. That view stresses the central tension embedded in the MAP: the trade-off between readiness now and maritime industrial resilience later.<a href="#_ftn6" id="_ftnref6">[6]</a>

The MAP is comprised of four strategic pillars: (i)&nbsp;Rebuilding U.S. Shipbuilding Capacity; (ii)&nbsp;Reforming Workforce Education and Training; (iii)&nbsp;Protecting the Maritime Industrial Base; and (iv)&nbsp;National Security, Economic Security, and Industrial Resilience (the Pillars).<a href="#_ftn7" id="_ftnref7">[7]</a> The Administration aims to pursue these Pillars through a series of executive and regulatory actions alongside a series of funding requests and legislative agendas that require U.S. Congressional action. The MAP also recommends deregulation in the form of eliminating outdated and unnecessary regulations, streamlining compliance processes, and clarifying remaining regulations to improve regulatory efficiency and facilitate the implementation of the Pillars.<a href="#_ftn8" id="_ftnref8">[8]</a>

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Pillar&nbsp;I aims to grow domestic shipbuilding capacity by creating incentives and policies to encourage investment in the U.S. maritime sector with the goals of increasing demand for U.S.-built ships, bringing supply chains back to the United States, and expanding the U.S.-flagged commercial fleet.<a href="#_ftn9" id="_ftnref9">[9]</a> A key part of Pillar&nbsp;I is the introduction of Maritime Prosperity Zones to be selected by the U.S. Secretary of Commerce in consultation with various U.S. Government agencies.<a href="#_ftn10" id="_ftnref10">[10]</a> The program would identify 100 coastal zones for maritime development, focusing on connecting shipbuilders with suppliers, enhancing workforce training, and adopting advanced manufacturing practices,<a href="#_ftn11" id="_ftnref11">[11]</a> all with the aim of boosting production and rebuilding necessary maritime infrastructure.

Pillar&nbsp;II targets labor and skills shortages in the maritime sector to ensure that enough skilled U.S. workers are available to support the MAP’s ambitions. It calls for educational reforms and increased funding for the U.S. Merchant Marine Academy, increasing support for state maritime academies, expanding access to maritime-trade training, and creating a gross income-tax exclusion for the income U.S. merchant mariners earn while employed on U.S.-flagged vessels operating on international routes.<a href="#_ftn12" id="_ftnref12">[12]</a>

Pillar&nbsp;III addresses the competitive disadvantages faced by U.S. maritime interests by identifying foreign shipbuilding strength as a structural problem. Pillar III proposes more efficient U.S. Government vessel procurement and improvements to cargo preference rules that favor U.S.-flagged vessels for U.S. Government cargos as tools to shift demand back to Jones Act-qualified and other U.S.-flagged vessels.<a href="#_ftn13" id="_ftnref13">[13]</a> These initiatives and Pillar III’s proposed Land Port Maintenance Tax, which would impose fees on merchandise imported through U.S. land ports<a href="#_ftn14" id="_ftnref14">[14]</a> similar to those imposed on merchandise imported through U.S. seaports under the U.S. Harbor Maintenance Tax, require further action that the Administration is unlikely to achieve without legislation passed by the U.S. Congress.

Pillar&nbsp;IV spotlights national security risks due to limited U.S. maritime capacity, particularly the risk of reliance on non-U.S. maritime-related industries in a divided world. Through this Pillar, the Administration seeks to leverage a stronger U.S.-built and -flagged merchant fleet to support national security.<a href="#_ftn15" id="_ftnref15">[15]</a> Proposed initiatives include increased funding for the Maritime Security Program and Tanker Security Program,<a href="#_ftn16" id="_ftnref16">[16]</a> as well as the establishment of a Strategic Commercial Fleet and a Maritime Security Trust Fund.<a href="#_ftn17" id="_ftnref17">[17]</a> Together, these measures are intended to pivot the United States away from reliance on foreign-built vessels and foreign maritime supply chains and to ensure the United States has the ability to build, repair and supply vessels in the United States, and crew these vessels with highly-trained U.S. mariners.<a href="#_ftn18" id="_ftnref18">[18]</a>

Pillar IV also aims to strengthen the U.S. Maritime Industrial Base’s resilience and modernize shipyards with advanced technologies like automated and digital manufacturing, initiatives that would prioritize robotic and autonomous systems, and policies for securing access to Arctic waterways for commercial use and recapitalizing the nation’s National Defense Reserve Fleet and Ready Reserve Force, all with the goal of boosting U.S. national and economic security.<a href="#_ftn19" id="_ftnref19">[19]</a>

B. Implementation and Legislative Considerations

Together, the MAP initiatives are likely to proceed on two tracks: longer-term legislative initiatives that require U.S. Congressional approval, and near-term measures taken through executive action. The U.S. Congress has already begun its consideration of some of the initiatives with bills like the proposed Shipbuilding and Harbor Infrastructure for Prosperity and Security (SHIPS) for America Act of 2025, which was originally introduced in the U.S. Congress in December 2024 and reintroduced with revisions in April 2025. Some aspects of the MAP may advance incrementally through executive action, but the most transformative elements are likely to require sustained legislative action.<a href="#_ftn20" id="_ftnref20">[20]</a>

1. Likely to Require U.S. Congressional Approval

The following MAP initiatives will likely require legislative approval in the form of an act of the U.S. Congress, and approval by the president:

a. Universal Fee on Foreign-Built Vessels Calling at U.S. Ports

The MAP proposes fees on foreign-built vessels entering U.S. ports to encourage demand for U.S.-built vessels. The proposal would assess a fee on imported cargo loads on a yet-to-be-finalized sliding scale, with a low-end fee of one U.S. cent per kilogram that would generate an estimated US$66 billion in fees over 10 years, and a high-end fee of 25 U.S. cents per kilogram that would generate US$1.5 trillion in fees over the same period. These fees are similar to the fees on PRC-owned, -operated and -built vessels entering U.S. ports that were imposed and subsequently suspended by the U.S. Trade Representative in late 2025<a href="#_ftn21" id="_ftnref21">[21]</a> but would apply to all foreign-built vessels and would likely require new legislation or legislative amendments to be passed by the U.S. Congress.

The MAP also proposes a fee on goods entering the United States by land borders. This fee, which would be called the Land Port Maintenance Tax, would be similar to the U.S. Harbor Maintenance Tax on goods entering the United States through U.S. ports.<a href="#_ftn22" id="_ftnref22">[22]</a> The Administration sees the Land Port Maintenance Tax as necessary to ensure that cargo that would otherwise be imported into the United States through U.S. ports is not transshipped into the United States through Canada and Mexico over land borders in avoidance of the U.S. Harbor Maintenance Tax and the MAP’s proposed U.S. port-entry fees on foreign-built vessels.<a href="#_ftn23" id="_ftnref23">[23]</a> While this measure could establish a significant new revenue stream and mitigate losses in revenue from the transshipment through Canada and Mexico, it is also likely to meet resistance from stakeholders involved in cross-border trade.<a href="#_ftn24" id="_ftnref24">[24]</a>

c. Major Funding &amp; Appropriations for Shipbuilding &amp; Yard Modernization

The MAP calls for substantial federal investment to expand shipyard capacity and to modernize aging infrastructure through expanded funding and tax incentives, including under existing programs such as the Title XI Federal Ship Financing Program, the Capital Construction Fund, and the Small Shipyard Grant Program, as well as production tax credits and accelerated depreciation.<a href="#_ftn25" id="_ftnref25">[25]</a>

d. Statutory Changes to Cargo Preference Laws and Creation of the Maritime Security Trust Fund

The MAP also aims to ensure that U.S.-flagged vessels transport a larger share of government-related cargo by proposing changes to U.S. cargo preference laws.<a href="#_ftn26" id="_ftnref26">[26]</a> Congressional action would be required for any modification of existing cargo preference laws and to allocate any U.S. Government funds to the Maritime Security Trust Fund.

The following MAP initiatives may not need legislative action or an act of the U.S. Congress:

The MAP directs the Administration to increase the use of trade enforcement authorities to scrutinize foreign maritime systems, with particular focus on investigating the PRC. Through investigations, administrative actions and enforcement proceedings, the Administration may impose tariffs, restrictions or other remedial measures, at their discretion.<a href="#_ftn27" id="_ftnref27">[27]</a>

b. Modernizing Regulations to Streamline Entry into the Maritime Workforce and Align Training with Industry Needs

The MAP points to agency rulemaking as a key tool for correcting inefficiencies in maritime credentialing, certification, permitting and training.<a href="#_ftn28" id="_ftnref28">[28]</a> The MAP identifies deregulatory opportunities, such as removing outdated requirements, simplifying compliance and adapting rules for emerging technologies, especially autonomous vessels.<a href="#_ftn29" id="_ftnref29">[29]</a>

c. Encouraging Interagency Coordination and Strategic Planning

The success of the MAP depends on coordination across multiple federal agencies, including the Departments of Transportation, Defense and Homeland Security. Although these efforts are less visible than legislative or regulatory actions, the MAP indicates that they can play a critical role in shaping policy direction for implementation of its objectives.<a href="#_ftn30" id="_ftnref30">[30]</a>

d. Utilizing Authorized Buy-American Procurement Preferences

To the extent authorized under current law, the MAP indicates that federal agencies may expand the application of domestic sourcing preferences consistent with existing Buy-American requirements. From a supply-and-demand perspective, this would include strengthening the definition of “U.S.-built” to increase supplier capacity.<a href="#_ftn31" id="_ftnref31">[31]</a> While narrower in scope than new legislative mandates, these procurement decisions can still influence the domestic supply chain and production, such as increasing critical component production within the United States through price incentives.<a href="#_ftn32" id="_ftnref32">[32]</a>

The Administration has already commenced its mission under the MAP to deregulate and unburden the maritime regulatory structure. This will entail federal agencies updating compliance to be less burdensome, removing outdated rules, and overall modernizing the existing maritime framework to allow for innovative technologies and greater efficiency.<a href="#_ftn33" id="_ftnref33">[33]</a>

Implementation of the MAP may take time to proceed through executive action and the legislative process, but the direction to rebuild the shipbuilding industry in the United States under the Administration is clear. This is a shift toward government involvement in the maritime sector that has not been seen in decades, creating new opportunities across shipbuilding, finance, workforce improvements, and the development of related infrastructure. While many of the MAP’s most ambitious initiatives are still contingent on U.S. Congressional approval and appropriations, for domestic stakeholders, the MAP marks the beginning of a realignment of U.S. maritime policy and investment to the demands of a more competitive and interconnected world economy.

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<a href="#_ftnref1" id="_ftn1">[1]</a> The White House, America’s Maritime Action Plan (Feb. 2026) (<a href="https://www.whitehouse.gov/wp-content/uploads/2026/02/Restoring-Americas-Maritime-Dominance.pdf">https://www.whitehouse.gov/wp-content/uploads/2026/02/Restoring-Americas-Maritime-Dominance.pdf</a>) (the “Maritime Action Plan”).

<a href="#_ftnref2" id="_ftn2">[2]</a> See Eric Haun, White House Releases Maritime Action Plan to Rebuild US Shipbuilding, WorkBoat, Feb. 13, 2026 (<a href="https://www.workboat.com/white-house-releases-maritime-action-plan-to-rebuild-us-shipbuilding/">https://www.workboat.com/white-house-releases-maritime-action-plan-to-rebuild-us-shipbuilding/</a>).

<a href="#_ftnref3" id="_ftn3">[3]</a> See Inti Pacheco &amp; Costas Paris, In Shipbuilding, the U.S. Is Tiny and Rusty, Wall St. J., Mar. 2, 2025 (<a href="https://www.wsj.com/business/logistics/in-shipbuilding-the-u-s-is-tiny-and-rusty-03fb214e?mod=article_inline">https://www.wsj.com/business/logistics/in-shipbuilding-the-u-s-is-tiny-and-rusty-03fb214e?mod=article_inline</a>).

<a href="#_ftnref4" id="_ftn4">[4]</a> See Gary Howard, Spin Takes US Maritime Action Plan Away from Shipbuilding, Seatrade Maritime News (Mar. 18, 2026) (<a href="https://www.seatrade-maritime.com/regulations/us-maritime-action-plan-spins-away-from-shipbuilding">https://www.seatrade-maritime.com/regulations/us-maritime-action-plan-spins-away-from-shipbuilding</a>).

<a href="#_ftnref5" id="_ftn5">[5]</a> See Haun, supra note 2; see also Capt. John Konrad, Trump Unveils White House Maritime Action Plan to Restore U.S. Seapower, gCaptain Daily (Feb. 13, 2026) (<a href="https://gcaptain.com/white-house-maritime-action-plan/">https://gcaptain.com/white-house-maritime-action-plan/</a>).

<a href="#_ftnref6" id="_ftn6">[6]</a> See Howard, supra note 4.

<a href="#_ftnref7" id="_ftn7">[7]</a> See Maritime Action Plan at ii.

<a href="#_ftnref8" id="_ftn8">[8]</a> See id. at 32.

<a href="#_ftnref9" id="_ftn9">[9]</a> See id. at 2-8.

<a href="#_ftnref10" id="_ftn10">[10]</a> See id. at 6.

<a href="#_ftnref11" id="_ftn11">[11]</a> See id.

<a href="#_ftnref12" id="_ftn12">[12]</a> See id. at 9-14.

<a href="#_ftnref13" id="_ftn13">[13]</a> See id. at 15-19.

<a href="#_ftnref14" id="_ftn14">[14]</a> See id. at 16.

<a href="#_ftnref15" id="_ftn15">[15]</a> See id. at 20-27.

<a href="#_ftnref16" id="_ftn16">[16]</a> The Maritime Security Program (MSP) maintains a fleet of commercially viable, militarily useful merchant ships active in international trade. The MSP fleet is available to support U.S. Department of Defense sustainment sealift requirements during times of conflict or in other national emergencies.  <a>See U.S. Department of Transportation, Maritime Administration, </a>Maritime Security Program (MSP) (<a href="https://www.maritime.dot.gov/national-security/strategic-sealift/maritime-security-program-msp">https://www.maritime.dot.gov/national-security/strategic-sealift/maritime-security-program-msp</a>). The Tanker Security Program is a similar program specifically for tanker vessels. See U.S. Department of Transportation, Maritime Administration, Tanker Security Program  (<a href="https://www.maritime.dot.gov/national-security/strategic-sealift/tanker-security-program">https://www.maritime.dot.gov/national-security/strategic-sealift/tanker-security-program</a>).

<a href="#_ftnref17" id="_ftn17">[17]</a> See Maritime Action Plan at 20-27.

<a href="#_ftnref18" id="_ftn18">[18]</a> See id. at 20-27.

<a href="#_ftnref19" id="_ftn19">[19]</a> See id. For retention of vessels valued for national defense purposes, the U.S. Maritime Administration manages and maintains a fleet of inactive, U.S. Government-owned vessels known as the National Defense Reserve Fleet (NDRF) to provide a reserve of approximately 100 vessels – mostly militarily useful former commercial ships to support national defense and contingencies. The NDRF includes the Ready Reserve Force (RRF), which is maintained at a higher level of readiness. See U.S. Department of Transportation, Maritime Administration, National Defense Reserve Fleet (NDRF) (<a href="https://www.maritime.dot.gov/national-defense-reserve-fleet">https://www.maritime.dot.gov/national-defense-reserve-fleet</a>).

<a href="#_ftnref20" id="_ftn20">[20]</a> See Howard, supra note 4.

<a href="#_ftnref21" id="_ftn21">[21]</a> See John F. Imhof Jr., Port-Entry Fees on Pause: The USTR Suspends Section 301 Fees on China-Linked Vessels, Vedder Global Transportation Finance Newsletter (Dec. 2025) (<a href="https://www.vedder.com/insights-events/port-entry-fees-on-pause-the-ustr-suspends-section-301-fees-on-china-linked-vessels/">https://www.vedder.com/insights-events/port-entry-fees-on-pause-the-ustr-suspends-section-301-fees-on-china-linked-vessels/</a>).

<a href="#_ftnref22" id="_ftn22">[22]</a> See Maritime Action Plan at 16.

<a href="#_ftnref23" id="_ftn23">[23]</a> See id. See also Executive Order, Restoring America’s Maritime Dominance, Apr. 9, 2025, § 6(b) (<a href="https://www.whitehouse.gov/presidential-actions/2025/04/restoring-americas-maritime-dominance/">https://www.whitehouse.gov/presidential-actions/2025/04/restoring-americas-maritime-dominance/</a>).

<a href="#_ftnref24" id="_ftn24">[24]</a> See Haun, supra note 2.

<a href="#_ftnref25" id="_ftn25">[25]</a> See Maritime Action Plan at 7-8. The Title XI Federal Ship Financing Program provides long-term loans by the U.S. Maritime Administration to promote the growth and modernization of the U.S. Merchant Marine and U.S. shipyards. See U.S. Department of Transportation, Maritime Administration, Federal Ship Financing Program (Title XI) (<a href="https://www.maritime.dot.gov/grants/title-xi/federal-ship-financing-program-title-xi">https://www.maritime.dot.gov/grants/title-xi/federal-ship-financing-program-title-xi</a>). The Capital Construction Fund (CCF) Program encourages construction, reconstruction or acquisition of vessels through the deferment of U.S. federal income taxes on certain deposits of money or other property placed into a qualifying fund.  See U.S. Department of Transportation, Maritime Administration, Capital Construction Fund (<a href="https://www.maritime.dot.gov/grants/capital-construction-fund">https://www.maritime.dot.gov/grants/capital-construction-fund</a>). The Small Shipyard Grant Program is designed to support small shipyard projects that make capital and related improvements; or provide training for workers in shipbuilding, ship repair and associated industries. See U.S. Department of Transportation, Maritime Administration, Small Shipyard Grants (<a href="https://www.maritime.dot.gov/grants-finances/small-shipyard-grants">https://www.maritime.dot.gov/grants-finances/small-shipyard-grants</a>).

<a href="#_ftnref26" id="_ftn26">[26]</a> See Maritime Action Plan at 15-16. The cargo preference laws are the U.S. laws, regulations and policies that require the use of U.S.-flagged vessels in the movement of cargo that is owned, procured, furnished or financed by the U.S. Government. They also apply to cargo that is being shipped under an agreement of the U.S. Government, or as part of a Government program.  See U.S. Department of Transportation, Maritime Administration, Cargo Preference (<a href="https://www.maritime.dot.gov/ports/cargo-preference/cargo-preference">https://www.maritime.dot.gov/ports/cargo-preference/cargo-preference</a>).

<a href="#_ftnref27" id="_ftn27">[27]</a> See Maritime Action Plan at 19.

<a href="#_ftnref28" id="_ftn28">[28]</a> See id. at 31, 33.

<a href="#_ftnref29" id="_ftn29">[29]</a> See id. at 9-10, 14, 30-31.

<a href="#_ftnref30" id="_ftn30">[30]</a> See id. at 32.

<a href="#_ftnref31" id="_ftn31">[31]</a> See id. at 7.

<a href="#_ftnref32" id="_ftn32">[32]</a> See id. at 7, 21.

<a href="#_ftnref33" id="_ftn33">[33]</a> See id. at 28-32.

The Duality of the U.S. Maritime Action Plan: Near-Term Impact and Long-Term Challenges

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