Transport, Logistics and Shipping in China

The transport sector in China: an overview for investors and operators

The transport sector in China is the backbone of the world's largest trading economy. China has many of the world's busiest container ports, the largest high-speed rail network, one of the biggest aviation markets and the largest shipbuilding industry. It is also home to major shipowners, lessors, logistics groups and port operators that invest across Asia, Africa, Europe and Latin America. For foreign businesses, the sector offers opportunities in shipping, aviation, logistics, leasing, equipment and infrastructure, but it is shaped by strategic considerations at every level.

Three features distinguish the sector. First, state-owned enterprises dominate key infrastructure: ports, railways, airports and the major airlines and shipping lines. Second, several transport activities remain on the foreign investment negative list, so ownership structure matters. Third, transport has become a front line in trade and technology competition, from US port fees on Chinese-built ships to drone rules and data controls on logistics platforms.

This page explains the regulatory landscape for the transport sector in China, introduces our pages on aviation, ports and rail, and shipping and maritime, and highlights the cross-border issues that affect investment, financing and disputes. It is general information about the Chinese legal environment, not PRC legal advice.

Regulators and legal framework

Transport regulation is divided by mode, with cross-cutting roles for planning, customs, competition and data regulators.

The legislative framework was substantially updated in 2025 and 2026. The revised Maritime Code, adopted on 28 October 2025, took effect on 1 May 2026 with 16 chapters and 310 articles. The revised Civil Aviation Law, adopted in December 2025, took effect on 1 July 2026, with new provisions supporting the low-altitude economy and requiring airworthiness certification for civil drones unless exempted.

The revised Maritime Code

The Maritime Code revision is the first comprehensive overhaul since 1992. It brings domestic coastal cargo carriage within the Code, gives electronic transport records equal legal status to paper documents when statutory conditions are met, adds a chapter on liability for ship oil pollution damage with compulsory insurance, raises passenger compensation limits and expands the conflict-of-laws rules on ship ownership, mortgages, liens and priority of claims. Contracts for carriage of goods with a loading or discharge port in mainland China must apply the Code's cargo carriage chapter. These changes affect bills of lading, charterparties, ship finance documents and claims strategy.

Logistics, express delivery and road freight

Logistics is the most open and fragmented part of the sector. Road freight operators need operating permits for vehicles and drivers, and dangerous goods carriage carries additional licensing and safety obligations. Express delivery businesses need a licence from the postal authorities, although domestic delivery of letters is reserved to the state postal system. Freight platforms that match shippers and truck drivers are regulated as network freight operators, with obligations on verification of carriers, tax reporting and data security. Cold-chain, bonded warehousing and contract logistics are popular areas for foreign investment, often combined with logistics and industrial real estate.

Foreign investment in the transport sector in China

Most of the transport sector in China is open to foreign investment, but several activities remain restricted under the national negative list (2024 edition), whose transport items the NDRC has explained. The main restrictions are as follows.

• Domestic waterway transport: companies must be Chinese-controlled.
• Public air transport: airlines must be Chinese-controlled, a single foreign investor and its affiliates may hold no more than 25%, and the legal representative must be a Chinese national.
• General aviation: the legal representative must be a Chinese national, with further limits for certain categories of operation.
• Civil airports: construction and operation require the Chinese side to be the relatively largest shareholder.
• Prohibited: air traffic control, and postal companies and domestic express delivery of letters.

Outside these areas, foreign investors can generally own international shipping companies, shipping agencies, freight forwarders, logistics and warehousing businesses, port terminals (usually through joint ventures with port groups in practice), vehicle and equipment manufacturing and leasing businesses. Pilot free trade zones, including Shanghai's Lingang area and the Hainan Free Trade Port, offer additional openings, for example in international ship management, registration and certain coastal transshipment arrangements. Our page on market entry and foreign-invested enterprises explains the general rules.

Infrastructure concessions and project structures

Ports, airports, toll roads and urban rail are typically developed through concessions, joint ventures with local state-owned groups or public-private partnership structures. Rules on government and social capital cooperation were reformed in 2023, shifting emphasis towards user-pays projects and private participation, and concessions usually require government consent for transfers of interests. Foreign investors should look closely at tariff-setting mechanisms, government payment obligations, step-in rights and compensation on early termination. See PPP projects for the general framework.

Our pages on the transport sector in China

Our transport coverage is organised into three pages, each with a deeper look at the regulatory framework, transactions and disputes.

• Aviation: airline ownership limits, airport investment, the revised Civil Aviation Law, aircraft acquisition and leasing, the Cape Town Convention, drones and the low-altitude economy, and aviation disputes.
• Ports and rail: port terminal investment and concessions, port operations and tariffs, railway investment and rolling stock, multimodal logistics and the China–Europe rail corridor, and infrastructure projects abroad.
• Shipping and maritime: the revised Maritime Code, ship registration and finance, shipbuilding contracts, charterparties and bills of lading, sanctions and port fee measures, maritime courts and arbitration, and decarbonisation rules.

Related practice and sector pages include asset, aircraft and vessel finance and leasing, low-altitude economy, export controls and sanctions, international arbitration and Belt and Road.

Trade, sanctions and geopolitics

Transport, and shipping in particular, has been drawn directly into US–China trade tensions. Under a Section 301 action, the US Trade Representative introduced port fees on vessels owned or operated by Chinese entities and on Chinese-built vessels from 14 October 2025. China responded with special port charges on vessels owned, operated or built by US interests, and sanctions against certain US-linked shipping entities.

Following the trade arrangement reached in late 2025, both sides suspended their port fee measures for one year from 10 November 2025. In late October 2026 USTR proposed extending its suspension, which was due to end on 9 November 2026, to 9 January 2027; businesses should check the current status of both the US measures and China's reciprocal charges before fixing long-term charter and freight terms.

Other cross-border pressures include sanctions affecting tankers carrying Russian or Iranian oil, which have led to designations of vessels, shipowners and port operators; US and EU restrictions on Chinese port cranes and logistics software on security grounds; and investment screening of Chinese stakes in foreign ports and terminals. Chinese law adds countermeasures under the Anti-Foreign Sanctions Law and the Unreliable Entity List, which can create conflicting obligations for multinational operators. See Anti-Foreign Sanctions Law and blocking rules and China and the US.

Customs, bonded zones and multimodal transport

Customs supervision shapes how transport businesses operate in practice. Comprehensive bonded zones, free trade zones and the Hainan Free Trade Port allow goods to be stored, processed and transhipped with deferred or reduced duties. Multimodal arrangements, including sea-rail links and the China–Europe Railway Express, depend on customs transit procedures and electronic documentation. The revised Maritime Code's treatment of electronic records is expected to support wider use of electronic bills of lading in these chains.

Data and cybersecurity in transport

Transport and logistics businesses handle large volumes of data on cargo, routes, vessels, vehicles and passengers. Some of it may be classed as important data under the Data Security Law, and operators of key transport systems may be critical information infrastructure operators with additional obligations, including data localisation and security reviews for certain procurement. Transfers of passenger and logistics data abroad require a lawful route under the PIPL and data export rules. At the same time, the US and some EU states have restricted Chinese logistics software and port equipment on security grounds. See our page on cross-border data transfer.

Decarbonisation

Climate rules are reshaping transport economics. The EU Emissions Trading System has applied to shipping since 2024 on a phased basis, with surrender obligations covering all reported emissions from 2026, and the FuelEU Maritime regulation has applied since January 2025. At the International Maritime Organization, member states agreed in October 2025 to postpone adoption of the proposed global net-zero framework for one year. In aviation, CORSIA offsetting obligations and sustainable aviation fuel mandates in the EU and elsewhere affect airlines serving China. Chinese shipyards and shipowners are major players in methanol, LNG and ammonia-ready vessels.

Finance, transactions and disputes in the transport sector in China

Chinese leasing companies are among the largest owners and financiers of aircraft and ships worldwide, and Chinese shipyards build a majority of new commercial tonnage by gross tonnage. That creates a steady flow of cross-border work: shipbuilding contracts and refund guarantees, sale and leaseback transactions, aircraft operating leases, export credit financing and portfolio trades. Lessors frequently use special purpose vehicles in Tianjin Dongjiang, Shanghai, Guangzhou Nansha, Hainan and Hong Kong, each with its own tax and customs features.

Key transaction issues

• Governing law and forum: English law and London or Hong Kong arbitration remain common in shipbuilding and leasing, while the revised Maritime Code mandates Chinese law for certain carriage contracts with Chinese ports.
• Security and registration: ship mortgages and aircraft interests must be registered correctly, including under the Cape Town Convention for aircraft, to which China is a party.
• Foreign exchange: cross-border lease rentals, guarantees and loans must fit SAFE rules on registration and quotas.
• Sanctions and export controls: aircraft parts and avionics are subject to US export controls; vessel trades must screen for sanctioned parties and trading patterns.
• Merger control: consolidation among shipping lines, port operators and logistics groups can require SAMR review under the 2024 thresholds.

Hong Kong as a maritime and aviation hub

Hong Kong remains central to the transport sector in China for finance, registration and disputes. It operates one of the world's largest ship registries, offers tax concessions for ship leasing, ship management and aircraft leasing, and is a leading seat for maritime arbitration. Many Chinese shipowners and lessors hold assets through Hong Kong companies, and lenders often prefer Hong Kong or English law documentation. The Mainland–Hong Kong arrangements on interim measures and on recognition of judgments and awards make Hong Kong a practical base for securing and enforcing claims against mainland parties.

Disputes

China has a specialised system of maritime courts with exclusive jurisdiction over maritime cases at first instance, and the China Maritime Arbitration Commission handles maritime arbitration. Ship arrest in Chinese ports is a commonly used security tool. Hong Kong, London and Singapore remain popular seats for international shipping and aviation disputes, and arbitral awards are enforceable in mainland China under the New York Convention and, for Hong Kong awards, the Mainland–Hong Kong arrangement. See Hong Kong courts and HKIAC.

Outlook and practical priorities

Several developments will shape the transport sector in China over 2026 and 2027.

1. Implementing the new Maritime Code: expect Supreme People's Court interpretations and new case law on electronic records, port operators as actual carriers and oil pollution insurance. Contract templates should be updated now.
2. Low-altitude economy rules: the revised Civil Aviation Law and CAAC rules on drone airworthiness, operations and airspace will continue to develop, with local pilot programmes for drone logistics and eVTOL services. See our low-altitude economy page.
3. Port fee and sanctions measures: the status of US Section 301 port fees and China's countermeasures beyond January 2027 is a key variable for owners, charterers and shipyards.
4. Data and logistics platforms: data security rules on logistics, vehicle and port data, and foreign restrictions on Chinese logistics software, will affect technology choices.
5. Outbound infrastructure: Chinese investment in ports, railways and airports abroad will face closer screening in some markets and strong demand in others, particularly in Southeast Asia, the Middle East, Africa and Latin America.

Chinese transport groups going abroad

Chinese port operators, shipping lines, logistics companies, rail builders and airlines continue to invest overseas. Outbound investments need NDRC and MOFCOM filings or approvals and SAFE registration in China, and in the host country they may face foreign investment screening, concession tenders, labour and environmental rules and local content requirements. Security concerns around ports, cranes and logistics data mean that deal certainty in some markets now depends on mitigation commitments. Careful choice of investment vehicle, often in Hong Kong or Singapore, and of dispute resolution and treaty protection can make a significant difference. See outbound direct investment approvals and bilateral investment treaties and political risk.

Common mistakes

• Assuming that foreign-law choice in a bill of lading or charter will always be respected in Chinese proceedings, without checking the mandatory provisions of the new Maritime Code.
• Overlooking negative list limits when investing in airlines, general aviation, airports or domestic shipping through layered structures.
• Failing to screen vessel histories and counterparties for sanctions exposure before sale, purchase or charter.
• Treating port and terminal concessions as freely transferable when they often require government consent.
• Assuming that a suspended trade measure, such as the port fees, will stay suspended, rather than building in clear cost-allocation clauses for its return.

How TRW & Co helps

We advise shipowners, lessors, airlines, logistics groups, port investors, lenders and Chinese transport companies investing abroad on the cross-border dimensions of their work. That includes structuring investments and joint ventures, negotiating shipbuilding, leasing, charter, concession and logistics contracts, advising on English, Hong Kong and other non-PRC laws, sanctions and export controls, and coordinating international arbitration. We manage multi-jurisdiction projects and due diligence. Where PRC legal opinions, regulatory filings or representation in Chinese maritime courts or other PRC proceedings are required, we work with licensed PRC law firms. To discuss a transport matter, contact our Shenzhen office.