War Risk Surcharge: What Carriers Can Bill and What to Check

In March 2026, the situation around the Strait of Hormuz led ocean carriers to add new charges. Hapag-Lloyd introduced a war risk surcharge of USD 1,500 per TEU for standard containers and USD 3,500 per reefer or special equipment container on cargo to and from the Upper Gulf, Persian and Arabian Gulf, applying to bookings issued on or after 2 March 2026 (Hapag-Lloyd customer advisory, March 2026). It also covered bookings issued but not yet shipped, and cargo already on the water but not yet discharged.

Fuel followed. Maersk introduced a temporary, non-refundable Emergency Bunker Surcharge of USD 400 per 40-foot dry container on long-haul headhaul routes (Maersk customer advisory, 10 March 2026, updated 18 March). Hapag-Lloyd ran an Emergency Fuel Surcharge alongside its regular fuel charge until it was discontinued from 1 July 2026 (Hapag-Lloyd, June 2026). The levels have been revised several times since. Maersk reset its Emergency Contingency Surcharge for cargo to Upper Gulf ports at USD 1,800 per 20-foot and USD 3,000 per 40-foot dry container from 16 May (Maersk, 20 May 2026), and added an Emergency Operational Cost Recovery surcharge of USD 500 per container on cargo to Bahrain, Qatar, Kuwait and Iraq from 17 September 2026 for non-regulated countries and 11 October for regulated ones such as the US (Maersk, 11 September 2026). The figures in this post are examples with their dates, not current rates.

What is a war risk surcharge, and how is it calculated?

A war risk surcharge is an additional charge a carrier adds to cargo moving to or from an area affected by conflict, to recover costs of operating there. Each carrier sets its own basis. Hapag-Lloyd's March 2026 charge, for example, was a fixed amount per TEU (twenty-foot equivalent unit) for standard containers and per container for reefer and special equipment, applied by the ports covered, not a percentage of the freight rate.

Hapag-Lloyd's advisory gives the reason as disruption across its network. What the shipper can see is the trigger: a list of countries and ports, and a date. Hapag-Lloyd's charge covered Iraq, Bahrain, Kuwait, Qatar, Oman, the United Arab Emirates, Yemen and the Saudi ports of Dammam and Jubail, and it is borne by the sea freight payer. Standard equipment is charged per TEU, so a 40-foot dry container counts as two TEU and bills USD 3,000. Reefers and special equipment are charged per container at USD 3,500, not on the TEU basis.

How does an emergency fuel surcharge differ from the normal bunker charge?

An emergency fuel surcharge is a temporary charge added on top of a carrier's regular fuel charge. Maersk says its Emergency Bunker Surcharge covers fuel price volatility beyond what its standard Fossil Fuel Fee covers, so the two appear as separate lines on the same shipment.

Hapag-Lloyd shows how the two meet. Its regular Marine Fuel Recovery charge is set quarterly and shown as a separate surcharge on the invoice and bill of lading. From 1 July 2026 the updated Q3 levels applied, and because they reflected the current fuel cost environment, the Emergency Fuel Surcharge was discontinued from the same date. Maersk's charge also depends on lane direction: USD 400 per 40-foot dry container on long-haul headhaul, USD 200 on backhaul or intra-trade lanes.

Can a carrier add a surcharge mid-contract?

Whether a carrier can add a surcharge during a contract depends on the contract terms, any tariff incorporated into it and the governing law. Hapag-Lloyd made its Gulf charge under clause 17 of its bill of lading, which its advisory says permits the modification or termination of contracts of carriage under specified circumstances. An all-in rate, or a clause listing the only surcharges that apply, is strong ground for refusing a new charge, but the contract, its incorporated tariffs and the applicable rules need reading before concluding that a line is not payable.

Regulation can set the timing. On US trades, an increase in the rates and charges in a filed tariff needs 30 days' notice, and Hapag-Lloyd's Gulf charge took effect for US cargo from 1 April 2026 rather than 2 March. In a statement posted on 23 March 2026, FMC Chairman Laura DiBella said she voted against carrier requests to apply war risk or conflict surcharges on less than 30 days' notice (FMC, 23 March 2026).

A surcharge missing from the rate card is not automatically wrong, but it is the line most likely to pass unchecked, and unchecked lines do not stay small. In the invoices we audited between May and September 2026, 161 emergency fuel and bunker surcharge lines and 16 war risk lines were billed with no contracted rate behind them, CHF 53,000 in total, and two of the war risk lines were billed twice. One war risk line, USD 4,000 for a 40-foot reefer into the Gulf, arrived on a separate invoice two weeks after the surcharge took effect, USD 500 above the carrier's published rate, and went through unchecked.

Why do surcharge lines get approved without a check?

Surcharge lines slip through when the invoice is compared with the price agreed at booking. Hapag-Lloyd's war risk surcharge applied to bookings already issued and to cargo already on the water, so those invoices carried a line the booking price never showed.

The amounts also move. Hapag-Lloyd withdrew its emergency fuel surcharge from 1 July and Maersk has revised its Gulf levels more than once, so a line that was correct in March may be wrong on a later invoice.

What should you check on the invoice line?

Our Invoice Approval module checks every invoice line against contracted rates before it is paid. A war risk or emergency fuel line with no contracted rate is surfaced for a decision instead of passing with the total. The same check applies to any charge a carrier adds after the contract is signed.