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HORMUZ SURCHARGES AND YOUR IMPORT FREIGHT: WHAT THE FMC'S 30-DAY RULE ACTUALLY MEANS

Alliance Freight Solutions • 11 min read • Published Apr 2026
Large container ship loaded with shipping containers sailing at sea, representing ocean freight affected by Hormuz surcharges

Maersk, CMA CGM, Hapag-Lloyd, and Zim have filed emergency surcharges of $1,500–$4,000 per FEU tied to the Strait of Hormuz closure. Every importer moving freight through Middle East lanes or Cape of Good Hope rerouting lanes is seeing new charges appear on invoices.

But here is what most importers do not know: the Federal Maritime Commission unanimously denied these carriers' requests to fast-track those surcharges. Under federal regulation, carriers must provide 30 days' notice before any cost increase takes effect on U.S. trades. Many of the surcharges filed in early March are not legally effective until mid-to-late April 2026.

This article explains what that means for your freight costs right now — and what you should do before the clock runs out.

What Is the FMC's 30-Day Surcharge Notice Rule?

Under 46 CFR 520.8, common carriers operating in U.S. trades must publish tariff changes at least 30 days before they take effect. This applies to any increase in rates, charges, or surcharges.

Carriers can file a Special Permission request with the FMC to shorten the notice period. In response to the Hormuz crisis, all four major carriers — Maersk, CMA CGM, Hapag-Lloyd, and Zim — filed Special Permission requests to fast-track their emergency surcharges. The FMC denied every one of them unanimously.

The Commission's official statement was clear: enforcement is active, and carriers who impose charges before the 30-day window expires are in violation of federal maritime law.

The practical implication: surcharges filed in early-to-mid March 2026 are not enforceable on U.S.-bound cargo until mid-to-late April 2026. If your carrier billed you before that effective date, you may have grounds to contest the charge.

Note: this 30-day rule applies specifically to U.S. trades. Other regulatory regimes — India's Directorate General of Shipping and the EU — are handling Hormuz surcharges under different frameworks.

How Much Are the Hormuz Surcharges — and Which Routes Are Affected?

The Strait of Hormuz closure has reduced maritime traffic through the strait by over 70% since early March. Carriers are rerouting via the Cape of Good Hope, adding 10–14 days of transit time per sailing.

Here is what the surcharge landscape looks like:

Who is affected beyond Middle East shippers? Any cargo on a lane where the carrier has rerouted via Cape of Good Hope. Any shipper whose carrier has filed a blanket surcharge covering multiple trade lanes. If your freight touches an ocean carrier operating through the affected region, check your latest invoices.

What Importers Should Check on Their Current Invoices

The FMC's 30-day rule does not automatically void surcharges. It sets the clock on when they become enforceable. Here is how to use that distinction:

Compare dates. Look at the surcharge "effective date" on your carrier's tariff filing versus the actual date the charge appeared on your invoice. If the invoice date falls before the 30-day notice period expired, the charge may not be enforceable.

Check the FMC tariff database. Carriers must publish surcharges in the FMC's public tariff system before the effective date. You can search by carrier name to find the exact filing and effective dates for any Hormuz-related surcharge.

Review your service contract. Many contracts include surcharge cap language, cost-based limitation clauses, or duration constraints. A newly filed Emergency Conflict Surcharge does not automatically override the terms of your existing service contract. Have your logistics counsel or freight broker review the specific language.

The question to ask your carrier: "What is the tariff filing date for this surcharge, and has the 30-day notice period been satisfied?"

Do not assume that every new surcharge on your invoice is automatically enforceable. You have standing to contest charges billed before effective dates.

The Broader Impact: What Hormuz Means for Landed Costs in Q2 2026

Even within the FMC's enforcement window, the Hormuz disruption is reshaping landed costs for importers across multiple dimensions:

Transit time is the immediate cost. Cape of Good Hope rerouting adds 10–14 days per sailing. That is inventory carrying cost, delayed deliveries, and potential stockout risk — all hitting before any surcharge takes effect.

Fuel surcharges on domestic freight are rising. The Hormuz strait handles roughly 20% of global seaborne oil. Diesel prices are being pushed higher as supply tightens. Importers should expect drayage fuel surcharges to increase in coming weeks, tracked against the EIA weekly diesel index.

Houston is the primary diversion port for Middle East and Gulf trade. Importers sourcing from UAE, Saudi Arabia, or Qatar should expect increased vessel traffic and potential congestion at Houston Barbours Cut and Bayport terminals through Q2.

Newark is already congested. APMT terminal at Newark is running approximately 84-hour vessel wait times versus 18 hours at Maher terminals. Combined with oil-driven surcharges, importers routing through Newark should build buffer time into Q2 schedules.

The intermodal opportunity. While truckload spot rates are recovering into Q2, intermodal rates remain near historic lows. The mode spread — the cost difference between trucking and rail — is the widest it has been in years. For domestic legs over 500 miles, switching from over-the-road to intermodal can offset a significant portion of the ocean-side cost increases.

What Importers Should Do Before April Surcharges Take Effect

Four concrete actions to take now:

  1. Pull your carrier tariff filings. Log into the FMC tariff database and confirm the filing date for any Hormuz-related surcharge on your lanes. If the effective date is post-April 15, any invoice dated before then may be challengeable.

  2. Review your service contracts. Many contracts have cap provisions or cost-based limitations on surcharges. A new ECS filing does not automatically override your contract terms. Have your logistics team or broker review the specific language before paying contested charges.

  3. Reforecast landed costs with Cape routing in mind. Regardless of surcharge enforceability, transit times via the Cape of Good Hope are 10–14 days longer. Adjust inventory planning, delivery commitments, and safety stock calculations for Q2 accordingly.

  4. Lock in drayage and intermodal capacity now. Houston drayage demand will increase as Middle East trade diverts through Gulf ports. Los Angeles and Long Beach are absorbing tariff front-loading volume simultaneously. Q2 drayage capacity is tightening at the ports that matter most. Book before April.

How Alliance Freight Solutions Can Help

Alliance Freight Solutions is a licensed non-asset freight broker (MC-1607949, DOT-4177688) coordinating the full logistics chain for importers — from port to final destination.

We track FMC tariff filings and carrier surcharge activity weekly. We know which surcharges are enforceable on your lanes and which are still within the 30-day notice window.

Our port coverage spans Houston, LA/Long Beach, Savannah, Newark, Seattle/Tacoma, Miami, and Chicago intermodal — the ports where Hormuz-driven volume shifts are hitting hardest.

For importers affected by Hormuz-related surcharges, we can:

Request a freight cost review →

Frequently Asked Questions

Are the Hormuz surcharges already on my freight?

It depends on when your carrier filed the surcharge with the FMC. Carriers must publish tariff changes 30 days before they can charge shippers on U.S. trades. If your carrier filed in early-to-mid March, the effective date is not until mid-to-late April. Check your carrier's tariff filing directly on the FMC's tariff database.

Can I dispute a surcharge that was applied before the FMC effective date?

Yes. If a carrier billed you for a surcharge before the FMC-published effective date, you have grounds to dispute the charge. Review your service contract first — contract terms may provide additional protection beyond the FMC tariff rules.

Does the FMC rule protect me if I'm on a spot rate?

The 30-day notice requirement applies to published tariff changes, which covers most standard ocean rates. If you are on a spot booking without a formal service contract, your exposure may differ. Consult your broker for guidance on your specific booking terms.

My freight is from Asia, not the Middle East — am I affected?

Potentially yes. Carriers rerouting capacity via the Cape of Good Hope to avoid the Hormuz closure are applying fuel and transit surcharges across multiple trade lanes, including Asia-origin cargo. Check whether your carrier has filed any additional surcharges in the past 30 days.

Published by Alliance Freight Solutions | April 1, 2026

Sources: FMC Commission Statement on Hormuz Surcharges, 46 CFR 520.8, Container Mag — FMC Enforces 30-Day Surcharge Notice, FreightWaves — FMC Rejects Carrier Fast-Track Request, Maersk Hormuz Operational Update, C.H. Robinson March 2026 Freight Market Update