Why a 2026 Freight Year in Review Matters for Your 2027 Plan
Every January, analysts publish an outlook. Very few importers go back in November and check what actually happened. That is a mistake, because the gap between what the market expected for 2026 and what it delivered is the single most useful input you have for 2027 planning.
Coming into 2026, the consensus was simple. A record wave of new ships would flood the market, rates would fall, and tariff uncertainty would keep US demand soft. In February, that forecast looked right. Drewry's World Container Index fell to about $1,919 per 40ft container in the week ended February 19, down 38% year over year, and early-year US-China volumes were running roughly 30% below the prior year as buyers waited out tariff decisions.
Then the year broke in three directions at once. The Supreme Court struck down the IEEPA tariffs in February, setting off a chain of replacement tariffs and a refund fight that is still unresolved. The Strait of Hormuz effectively closed to mainstream container traffic in March, sending fuel costs and spot rates sharply higher on every major east-west lane. And CBP used the second half of the year to rebuild its enforcement toolkit, from suspending de minimis for all modes to voiding importer numbers on bad Form 5106 data.
The result: as of late October, the Drewry composite index was trading between roughly $4,400 and $4,600 per FEU, more than double its February low, in a year that was supposed to be defined by overcapacity. Importers who planned around the January consensus paid for it. Importers who built flexibility into contracts, inventory, and compliance did much better.
This guide covers:
- Tariffs: How the IEEPA ruling, the Section 122 surcharge, and the July Section 301 reset reshaped landed cost, and what is still open going into 2027.
- Rates and capacity: Why the overcapacity story was delayed, not cancelled, and what that means for contract season.
- Compliance: The enforcement changes that quietly raised the cost of getting paperwork wrong.
- Ports and labor: The demand swings and disruptions that tested US gateways.
- A scorecard: Which strategies paid off in 2026, which ones did not, and the signals worth watching in the first half of 2027.
It is written for importers moving 5 or more containers a month who need to turn a messy year into clear decisions for budgets, contracts, and sourcing. If you have already started 2027 budgeting, read this alongside our 2027 freight budget planning playbook.
Tariffs in 2026: From IEEPA to Section 301 in Six Months
No single factor moved landed cost more in 2026 than tariff policy. The headline rates mattered, but the bigger cost was the speed of change. Most importers filed entries under at least three different tariff regimes this year.
Phase 1: The IEEPA ruling (February)
In February, the Supreme Court struck down the tariffs imposed under the International Emergency Economic Powers Act (IEEPA). Section 301 and Section 232 duties were not affected. For importers, the ruling did two things at once. It removed a large layer of duty from future entries, and it created a potential refund claim on every IEEPA dollar already paid. Industry estimates of total refund exposure ran as high as $150 billion.
Phase 2: The Section 122 bridge (February to July)
The administration replaced IEEPA duties with a temporary 10% global surcharge under Section 122 of the Trade Act. It was blunt and uniform, which made planning easier in one way: country of origin barely changed your duty rate. But Section 122 has a hard statutory time limit, and everyone knew the clock was running.
Phase 3: The Section 301 reset (July 24)
At 12:01 a.m. ET on July 24, Section 122 expired and Section 301 duties of 10% to 12.5% on roughly 60 trading partners took effect in the same minute, covering an estimated 99.4% of US import value. On August 19, Section 338 tariffs of 50% on about $20 billion of Canadian dairy, vehicle, and alcohol imports followed, the first use of that authority in US history. We covered the details in our July 2026 tariff reset guide.
The shift from a flat surcharge to country-specific rates changed sourcing math. A 2.5 point spread between a 10% and a 12.5% origin is small per unit and large at volume. On a container carrying $250,000 of goods, that is $6,250 in duty difference, every container.
Phase 4: Refunds and the China calendar (Q4)
On October 8, the Court of International Trade certified a class of importers seeking IEEPA refunds who had not filed their own cases. That helps smaller importers, but it does not put money in accounts this quarter, and an appeal is likely. Meanwhile, the one-year pause on US port fees for China-linked vessels ran out on November 9, and the broader US-China truce runs to January 10, 2027. See our blog on the refund class action for the filing details.
What the tariff year taught us
- Duty stacking is now the default: Section 301, Section 232, AD/CVD, and MFN rates stack, and the stack differs by origin and changes by notice. A landed cost model with one "tariff" line is obsolete.
- Deadlines create freight surges: Every tariff deadline this year produced a booking spike and then an air pocket. July's record volumes were followed by soft September demand.
- Refunds are an asset to manage: Importers who reconciled IEEPA payments entry by entry early are in a far better position than those waiting on the class action.
- Documentation is leverage: Clean country-of-origin and classification files let you respond to a rate change in days, not weeks. A strong customs brokerage partner makes this routine.
Want to see how Cubic compares to your current forwarder?
Ocean Rates: The Overcapacity Year That Got Interrupted
The 2026 rate story has a clear shape: a slide in Q1, a shock in Q2, an elevated plateau through peak season, and a choppy Q4 where overcapacity and disruption are fighting each other.
Q1: The forecast plays out
The January outlooks were unanimous that supply would outrun demand. Xeneta described 2026 as a year defined by overcapacity, and forecasts called for spot rates down around 25% and long-term contracts down around 10%. By mid-February, the composite index had fallen below $2,000 per FEU. Importers who signed annual contracts in that window locked in some of the lowest base rates since before the Red Sea crisis.
Q2: Hormuz changes everything
When the Strait of Hormuz effectively closed in March, the direct container exposure looked small. Less than 2% of global container capacity normally passes through it. But the indirect effects were enormous:
- Fuel: Bunker prices spiked, and carriers passed through hundreds of millions of dollars a month in added fuel cost via emergency bunker surcharges.
- Stranded tonnage: Hundreds of vessels were caught in the region, including roughly 100 container ships, tying up capacity across networks.
- Network disruption: By June, only about 11 of 99 pre-crisis Gulf services were still operating. Cargo for the Gulf moved over land via Jeddah and Khor Fakkan.
- Spot rates: Asia to US rates were reported up 29% within weeks and up more than 100% from pre-war levels by early June.
At the same time, the long-awaited Suez normalization proved partial and fragile. Capacity returning to Suez routings caused severe congestion at North Europe hubs in May, and transits fell back again in July. The Cape detour, which had absorbed 10% to 12% of the global fleet, never fully unwound.
Q3 and Q4: An elevated, nervous plateau
Peak season pricing arrived early, with surcharges applied four to six weeks ahead of normal. Carriers then used blank sailings to defend rates through the softer post-tariff-deadline period. In late October, the index reached a 15-week high of about $4,585 per FEU on October 22, then slipped about 3% to $4,429 a week later as transpacific rates retreated on softer US demand.
The real lesson: the downturn is delayed, not cancelled
The orderbook still sits between 14 and 15.6 million TEU, with heavy deliveries through 2028. Every ship that is not stuck behind a chokepoint or sailing around Africa adds to supply. When disruption eases, it will ease quickly, and rates can fall faster than they rose. That is why the strongest 2026 contracts had index-linked components and why 2027 contracts should too.
| Period | Composite rate (approx. per FEU) | Main driver |
|---|---|---|
| Mid-February | $1,900 to $2,000 | Overcapacity, weak US-China demand |
| Late Q2 | Roughly double Q1 lows on many lanes | Hormuz closure, fuel surcharges |
| Late October | $4,400 to $4,600 | Disruption plus capacity management |
Treat these as directional benchmarks. Lane-level pricing varied widely, and transpacific spot quotes to the US West Coast ran well above the composite at points in October. If you want lane-level benchmarks for your own ocean freight program, we can pull them against your actual shipment history.
Carrier Behavior: Capacity Discipline as a Pricing Tool
If 2026 taught importers one thing about carriers, it is that published capacity is not available capacity. Carriers have become very good at managing supply to protect rates, and they used every tool this year.
Blank sailings were heavier and earlier
Around Golden Week, alliances blanked between 18% and 25% of scheduled capacity across the transpacific, Asia-Europe, and Mediterranean trades. The double holiday this year, Mid-Autumn Festival on September 25 followed by National Day from October 1 to 7, left factories only three working days in between. Importers who had not booked ahead found themselves competing for a deliberately shrunk network.
Surcharges did as much work as base rates
In many 2026 freight bills, the surcharge lines grew faster than the base rate. Emergency bunker surcharges tied to Hormuz, peak season surcharges applied early, congestion surcharges during the Suez reset, and "normalization" charges for fleet repositioning all appeared in the same year. Importers whose contracts capped surcharge pass-through, or tied them to a published fuel index, saw far smaller swings than those who accepted carrier tariffs as written.
Schedule reliability stayed fragile
Vessel bunching from Suez and Hormuz rerouting kept arrival patterns uneven. Rolled cargo was not only a result of overbooking. Vessels were reassigned between strings as carriers rebuilt networks, so a booking confirmation was often a placeholder until the box was loaded.
New cost layers from policy
The return of US port fees on China-linked vessels after November 9 is the latest example of a policy cost that lands on the carrier first and the shipper second. When the fees briefly applied in October 2025, carriers signaled they would pass them through. Expect the same in late 2026 unless USTR extends the pause.
How to use this in 2027 negotiations
- Negotiate allocation, not just price: A low rate with no guaranteed space was worth very little during Golden Week. Ask for minimum weekly allocation by lane, with a penalty or rebate for missed allocation.
- Define surcharges in the contract: List which surcharges apply, how they are calculated, and the index they reference. Exclude surcharges not named in the contract.
- Diversify across alliances: Splitting volume across at least two alliances reduces the damage from a single network's blank sailing program.
- Keep a spot share: Holding 15% to 25% of volume for spot let importers capture the Q1 lows and the late-October dip. Our contract season playbook covers how to structure this.
Compliance in 2026: The Year CBP Raised the Cost of Mistakes
Tariff headlines got the attention, but compliance changes probably had a larger long-term effect on how importers operate. In 2026, CBP shifted from a system where paperwork errors caused delays to one where they can stop your ability to import at all.
The key enforcement milestones
- Executive Order 14411 (June 3): Gave CBP 45, 90, and 180-day deadlines to overhaul importer of record eligibility, bonding, and disclosure. The final phase lands on November 30, 2026, right as holiday entries peak. Our EO 14411 compliance playbook walks through the requirements.
- De minimis suspended for all modes: The exemption that let low-value shipments enter duty-free is gone. A new postal informal entry process took effect July 24, and on October 22 CBP began enforcing exclusions for goods regulated by other agencies, Chapter 98 and 99 goods, and free trade agreement claims sent by mail.
- Form 5106 voiding (September 18): CBP can now immediately void an importer number if the identity data on file is inaccurate or incomplete, with no warning and no grace period. A voided number mid-shipment leaves cargo stuck at the port.
- Data-driven transshipment detection: CBP expanded its use of analytics to flag shipments where the declared origin does not match supplier, routing, or pricing patterns. With Section 301 rates now differing by country, origin fraud by suppliers became a direct risk to importers of record.
Europe moved in the same direction
European importers saw a parallel shift. The EU moved to end its low-value duty exemption with a flat per-item duty on small parcels, and ICS2 maritime filing requirements raised the bar on data quality before loading. The direction on both sides of the Atlantic is the same: more data, earlier, with real consequences for errors.
Demurrage and detention got real teeth
The FMC's billing rules for demurrage and detention matured this year. Samsung's $186 million complaint against CMA CGM, the largest D&D case ever filed at the FMC, shows how far shippers can push on invoices that do not meet the rules. For most importers, the practical lesson is to dispute non-compliant invoices on time, every time. See our D&D dispute playbook.
What changed in practice
The cost of a compliance error used to be a delay and maybe a penalty. In 2026, it can be a voided importer number, lost refund eligibility, a stopped shipment during peak, or a forced-labor detention. That changes the return on compliance work. A quarterly review of 5106 data, bond sufficiency, origin documentation, and classification now pays for itself many times over.
- Audit your importer identity: Confirm your Form 5106 data matches IRS records exactly, including physical address and contact details.
- Size your bond for 2027: Duty stacking increased duty paid, which can make existing continuous bonds insufficient.
- Document origin by SKU: Keep supplier declarations, production records, and bill of materials evidence ready for a CBP request.
- Move small parcels to formal channels: Samples and replacement parts that used to travel by mail need a new routing plan.
Demand, Ports, and Labor: How US Gateways Held Up
US import demand in 2026 was less a trend and more a series of reactions to deadlines. That pattern created feast-and-famine conditions at ports and inland networks.
The front-loading cycle
The year started weak, with US-China volumes down sharply as importers waited for tariff clarity. Once the IEEPA ruling and the Section 122 bridge set a known deadline, importers raced to land cargo before July 24. July volumes were on pace for a record near 2.47 million TEU. September then softened as inventory pulled forward from Q3 and Q4 sat in warehouses.
The cost of front-loading showed up later. Warehousing rates rose in key markets, inventory carrying costs climbed, and some importers found themselves overstocked on SKUs whose demand faded. Our inventory triage guide covers how to decide when stockpiling makes sense.
Port congestion moved around
US gateways mostly avoided the severe congestion seen in Europe during the Suez reset, but they did experience vessel bunching as rerouted services arrived in clusters. Terminals that handled surges well were those with spare yard capacity and strong rail connections. For importers, flexible discharge ports and pre-arranged drayage capacity were the difference between a one-day and a one-week dwell.
Labor risk returned to the West Coast
The coastwide ILWU longshore contract runs through 2028, so most importers assumed West Coast labor risk was off the table. The ILWU Local 26 watchmen dispute at Los Angeles and Long Beach proved otherwise. About 250 security workers, whose contract extension ran to November 4, staff terminals handling roughly 85% of Long Beach cargo and 33% of Los Angeles cargo. If other dockworkers decline to cross picket lines, a small unit can halt large terminals.
Lessons for 2027 port strategy
- Model the air pocket: Every tariff deadline will produce a surge and a lull. Plan warehouse space and drayage for both.
- Keep port options open: Contracts that allow discharge at alternate gateways with limited penalty proved valuable. Our port pair optimization guide covers alternatives.
- Watch small contracts: Labor risk does not only come from the big master agreements. Track side contracts at your primary terminals.
- Pre-book drayage and chassis: During surges, truck capacity became the bottleneck before terminal capacity did.
The 2026 Scorecard: What Worked and What Did Not
Looking across the importers we work with and the broader market, a clear pattern emerges. The winners in 2026 were not the ones who predicted the year correctly. Nobody predicted Hormuz. The winners built options that paid off no matter which way the year broke.
Strategies that paid off
- Hybrid contract structures: Importers with roughly 40% to 50% fixed, 30% to 40% index-linked, and 15% to 25% spot volume captured the Q1 lows, kept space through Q2 and Q3, and benefited from the late-October dip.
- Origin diversification with documentation: Shifting a share of production to Southeast Asia or Mexico helped, but only for importers who documented substantial transformation. Those who moved final assembly without the paperwork took on new transshipment risk instead.
- FTZ and bonded warehousing: Deferring duty until goods entered commerce gave importers flexibility to absorb the July rate change and protected cash flow.
- Early refund reconciliation: Importers who matched IEEPA payments to entries and filed protective claims early have stronger positions than those waiting on the class action.
- Booking ahead of known holidays: Importers who booked Golden Week cargo four to six weeks out avoided the worst of the blank sailing squeeze.
- Real-time visibility: Teams with live tracking and exception alerts caught rolled cargo and port changes in time to reroute or adjust inventory. See our guide on AI control towers.
Strategies that did not
- All-fixed annual contracts: Locking 100% of volume at February rates looked smart until carriers stopped honoring allocation in Q2 and pushed cargo to spot at much higher prices.
- Pure spot exposure: Importers relying entirely on spot paid peak prices from April through October with no space guarantee.
- Single-alliance concentration: One network's blank sailing program could remove a large share of an importer's weekly capacity overnight.
- Maximum front-loading: Pulling six months of inventory ahead of July cut duty but often cost more in warehousing, working capital, and markdowns than it saved.
- Treating compliance as a back-office task: Importers who ignored 5106 hygiene, bond sizing, and origin files found out the hard way that CBP's new tools act fast.
A simple self-assessment
Rate your 2026 performance on these five questions. Each "no" is a gap to close before 2027 contract season.
- Did your actual landed cost per container stay within 15% of budget for at least three of four quarters?
- Did your contracted allocation get honored at least 85% of the time in Q2 and Q3?
- Can you show, entry by entry, how much IEEPA duty you paid and the status of each refund claim?
- Do you have documented origin evidence for every SKU from a Section 301 country?
- Did you know about rolled or delayed containers before your customers did?
Seven Signals to Watch in the First Half of 2027
A year in review is only useful if it sharpens what you watch next. These are the signals most likely to move freight cost and risk for US and European importers in the first half of 2027.
1. The January 10 US-China truce expiry
The truce runs to January 10, 2027. An extension, a short lapse, or an escalation each implies a different duty rate on China-origin goods. Cargo shipped in the last weeks of December will land after that date, so your January entries carry real tariff risk. Run all three scenarios now.
2. Port fees on China-linked vessels
If the fees remain in effect after November 10, watch for carrier surcharge notices in December and January. Ask your forwarder which of your contracted vessels are affected and how charges will be passed through.
3. Hormuz and Suez normalization
This is the biggest swing factor for 2027 rates. If both chokepoints normalize, a large share of capacity returns to the market within months, and spot rates could fall sharply. If disruption persists, rates stay elevated. Build contracts that let you benefit from a decline without losing space if disruption continues.
4. Chinese New Year on February 6, 2027
Expect heavy blank sailings around the holiday and roughly ten weeks without new arrivals from a given supplier once production slowdowns and transit are combined. Our CNY 2027 production playbook covers order timing.
5. The IEEPA refund appeal
The government is likely to appeal the class certification. Track deadlines for your own protests and claims, and do not assume the class action will cover entries that are already finally liquidated.
6. Section 301 country revisions
Because the July 24 action is tied to forced-labor enforcement determinations, rates can change country by country as governments negotiate. A revision for Vietnam, India, or the EU could shift your sourcing math overnight. Set up alerts and keep your duty model modular.
7. Contract season pricing
Transpacific and Asia-Europe contract negotiations start in earnest in Q1. Carriers will point to 2026 disruption to justify higher rates. Importers will point to the orderbook. The outcome depends heavily on chokepoint news in January and February. Have your RFP ready to issue early and your benchmarks current. Our RFP template can help you evaluate partners.
For European importers
Watch the rollout of EU duty on low-value parcels, ongoing ICS2 data quality enforcement, and EU ETS carbon surcharges on Asia-Europe routes. Asia-Europe rates are also more exposed to Suez normalization than transpacific rates, so the potential downside is larger.
Turning the 2026 Review Into a 2027 Action Plan
2026 was supposed to be a quiet year of falling rates. Instead it delivered a Supreme Court tariff ruling, three tariff regimes in six months, a chokepoint closure that doubled rates, the end of de minimis, and a new generation of CBP enforcement tools. The lesson is not that forecasts are useless. It is that your freight program has to perform well across several outcomes, not just the most likely one.
Your next 30 days
- Close the compliance gaps: Verify Form 5106 data, confirm bond sufficiency, and prepare for EO 14411's November 30 phase.
- Reconcile IEEPA refunds: Build an entry-level ledger of IEEPA duties paid and the status of each claim or protest.
- Lock CNY space: Secure allocations for December and January sailings ahead of the February 6 holiday.
Your next 60 days
- Run the 2026 post-mortem: Compare actual landed cost by lane and quarter against budget. Separate base freight, surcharges, duties, and accessorials so you know where the variance came from.
- Model the January 10 scenarios: Price extension, lapse, and escalation cases for China-origin goods, and decide which SKUs to pull forward.
- Prepare your RFP: Use your 2026 data on allocation performance, surcharges, and dwell times to set clear requirements for 2027 partners.
Your next 90 days
- Sign a hybrid contract structure: Combine fixed, index-linked, and spot volume across at least two alliances, with named surcharges and minimum allocation.
- Finalize origin strategy: Decide which SKUs to dual-source, and make sure every alternative origin has documented substantial transformation.
- Set governance triggers: Agree in advance what rate, tariff, or chokepoint change triggers a reforecast or a shift in contract mix.
Importers who treated 2026 as a series of emergencies spent the year reacting. Those who used it to build flexible contracts, clean compliance files, and real-time visibility are going into 2027 with lower risk and better negotiating positions. Cubic combines ocean freight, air freight, customs brokerage, and cargo insurance on one platform, so you can see the full landed cost picture in one place. If you want a lane-by-lane review of your own 2026 performance, book a consultation with our team.