The US–China truce now ends on 10 January. The affiliates rule and China port fees return with it.

On 9 November 2026 the US Bureau of Industry and Security (BIS) published a final rule extending the suspension of its "affiliates rule" to 10 January 2027. Without it, the rule would have returned the next day. The US Trade Representative has done the same for the Section 301 port fees on China-linked vessels, now suspended until 9 January.

Both follow the two-month extension of the US–China trade truce agreed in September. Nothing has been resolved. The deadlines have moved once, by eight weeks, and they now fall on the same weekend.

What returns if the truce lapses

• 10 January 2027 · The affiliates rule. US export restrictions on companies on the Entity List, the Military End-User List and certain sanctions lists extend to any company they own 50 per cent or more.
• 10 January 2027 · Port fees. Fees on vessels owned, operated or built in China return, with tariffs on ship-to-shore cranes and cargo-handling equipment.
• 10 January 2027 · The wider truce. The truce’s tariff terms were extended to the same date. China’s pause on its October rare earth controls also runs to 10 January.

Each could be extended again, and many in Washington expect short extensions. None is guaranteed. Planning for an extension that does not come is the costly mistake.

Why this reaches beyond US companies

The affiliates rule follows the item, not the exporter. It applies to items subject to US export rules wherever they are shipped from. That includes US-origin goods, software and technology, and many products made with them.

• UK and EU manufacturers that build US-origin chips, modules or software into their products.
• Distributors and resellers selling into Asia through local subsidiaries.
• Data centre, energy and industrial suppliers whose customers sit inside large Chinese or Russian-linked groups.
• Shippers and charterers with China-linked tonnage on contracts that run past 9 January.

Why a name screen will miss it

The rule turns on ownership, not names. A customer can screen clean against every list and still be 60 per cent owned by a listed parent. Holdings of more than one listed party count together, even across different lists, and ownership through intermediate companies counts too.

The burden sits with the exporter. Suppose you know a listed party holds a stake in your customer. If you cannot establish its size, the rule expects you to find out or apply for a licence. Most screening tools do not trace ownership by default, and most customer files do not hold the information.

What to check now

• List the customers, distributors and consignees that receive items subject to US export rules.
• Trace each one’s ownership to the 50 per cent line, through intermediate holding companies.
• Flag any owned by a listed party, alone or in combination with others.
• Identify open orders that ship after 10 January, and decide whether to ship earlier, apply for a licence or hold.
• Review contracts and charter parties that run past 9 January for licence conditions and fee allocation.

What it is worth

One held shipment, or one export to a company you could not see was caught, costs more than finding out now. A licence application also takes time, so the decision has to be made well before January.

Meridian is offering this as a fixed-fee rescreen

Our Counterparty Rescreen covers up to 250 customers, distributors or suppliers in seven working days. We trace ownership to the 50 per cent line. We then test each name against the BIS Entity List and the UK, EU and US sanctions lists. You receive a list of the names that would be caught, with the ownership evidence behind each one.

Start by early December and you have the result with a month to spare. Send us the list and the markets you sell into, and we confirm scope the same working day. This is a review, not a legal opinion: licence decisions remain with you and your counsel.