War Risk Surcharge: What Carriers Can Bill and What to Check
Carriers added war risk and emergency fuel surcharges from March 2026 and have adjusted them since. Each one is a separate invoice line to check against your contract.
Update · 5 min · Alexandre de Perregaux, CEO, Intellyse · Published · Last updated
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).
The advisory tells you what the carrier intends to bill; the contract tells you what you agreed to pay.
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. Our audit of a German industrial materials manufacturer's ocean freight found terminal storage billed in 137 cases in two months, EUR 93K in total, on a charge that was not included in any rate card. Daily rates varied between EUR 56 and 58 with no fixed tariff, so there was no agreed rate to check each invoice against. A new war risk or fuel line with no contract reference enters the invoice the same way.
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?
- Match the advisory. For each new surcharge line, find the carrier advisory it refers to and note the amount, the equipment basis, the countries or ports covered, the effective date and any end date.
- Check the trigger date. Hapag-Lloyd's war risk surcharge reached cargo on the water but not yet discharged on 2 March, and US cargo only from 1 April; its emergency fuel surcharge was discontinued from 1 July. Maersk reset its Upper Gulf levels from 16 May. Compare those dates with the booking date, the bill of lading date and the shipment's movement dates, then check that the amount on the line matches the version of the advisory in force on the date that governs.
- Check the contract clause. Confirm whether your rate is all-in or subject to carrier surcharges, and whether war risk or emergency charges are named. If they are not, dispute the line and ask for the contractual basis in writing.
- Check for overlap. Where an emergency fuel surcharge and a regular fuel charge appear on the same invoice, ask the carrier which fuel cost each one covers.
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.
FAQ
How much is the war risk surcharge on Gulf cargo?
Hapag-Lloyd introduced USD 1,500 per TEU for standard containers and USD 3,500 per container for reefer and special equipment from 2 March 2026. Other carriers set their own amounts, so check each carrier's advisory.
Is an emergency fuel surcharge refundable?
Maersk describes its Emergency Bunker Surcharge as temporary and non-refundable. For other carriers, check the advisory and your contract for how and when the charge ends.
Can a carrier add a surcharge mid-contract?
It depends on the contract terms, any tariff incorporated into it and the governing law; Hapag-Lloyd, for example, relied on clause 17 of its bill of lading for its Gulf charge. If your rate is all-in or lists the permitted surcharges, ask for the contractual basis before paying.
