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**This TACAID includes legal opinion and analysis that does not necessarily reflect official U.S. government positions.

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USINDOPACOM J06/SJA TACAID SERIES

TOPIC: THE USE OF ROLL-ON / ROLL-OFF (RORO)

FERRIES IN MILITARY OPERATIONS

BLUF

 The direct insertion of troops into conflict is a belligerent act normally reserved for warships, yet the People’s 

Liberation Army (PLA) appears intent to use commercial ROROs (non-warships) for this purpose. 

 The PLA has integrated commercial ROROs into its amphibious invasion force rehearsals, but has taken no 

measures to distinguish ROROs from civilian ferries, such as by applying gray paint schemes or affixing markings 

consistent with state practice for military vessels. 

 Although ROROs engaged in war-supporting roles or operating under PLA control in conflict may be objects of a 

lawful attack, the PLA’s use of commercial ROROs serves as a means of deterrence by exploiting the lawabidingness of opposing forces that may be averse to use force against vessels that appear civilian in character. 

 By demonstrating intent to use commercial ROROs during an amphibious invasion, the PLA is eroding the principle 

of distinction under the law of armed conflict (LOAC) and obscuring crucial lines between warships and nonwarships, civilians and combatants, and civilian objects and military objectives. 

 In contrast, U.S. policy does not allow the use of non-warships for belligerent acts and permits arming of auxiliary 

vessels only for self-defense purposes. 

 Upholding the principle of distinction under the LOAC is critical to civilian harm mitigation in conflict. 

 As such, the international community should illuminate and condemn the PLA’s use of commercial ROROs to 

reduce risk of civilian harm in future conflicts and preserve fundamental principles of the LOAC. 

WHY THIS MATTERS

 The LOAC protects civilians, but if PLA practice continues to erode distinction such that parties to a conflict cannot 

effectively apply it, civilians will face greater risk of suffering in future conflicts. 

 The PLA’s use of commercial ROROs during amphibious invasion rehearsals undermines the current rules-based 

international order because it ignores legal principles under the LOAC and sets a dangerous precedent that 

increases risk of civilian harm not just in a conflict over Taiwan, but in future conflicts in other parts of the world 

where civilians may find themselves in harm’s way. 

 Upholding the efficacy of the LOAC now – in peacetime – is in the best interest of all nations because it ensures 

that all civilians will continue to enjoy protections they are due under international law. 

DETAILED DISCUSSION

 The People’s Republic of China’s (PRC) Military-Civil Fusion (MCF) strategy aggressively seeks to eliminate barriers 

between the PRC’s civilian and commercial sectors, and its military and defense industrial sectors.i

 The MCF’s guidelines for defense mobilization govern the use of commercial ROROs for military purposes. 

 In 2012, pursuant to the MCF, the PLA established “strategic projection support ship fleets” in major shipping 

companies consisting of commercial ROROs, container vessels, bulk carriers, tankers, auxiliary crane ships, barges, 

and semi-submersibles organized to provide transport for units, fuel, and cargo.

ii

1. Background
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 In 2016, the PRC’s National Defense Transportation Law compelled medium and large transport companies to use 

their “strategic projection support forces” to support PLA operations with “rapid, long-distance, and large-scale 

national defense transportation support.”iii

 The first publicized evidence of commercial RORO usage during PLA operations came in 2019 when the 15,000-

ton ferry, Bang Chui Dao, participated in a PLA amphibious assault exercise.iv In 2022, 30 separate commercial 

ROROs were observed in the integration of large-scale lift exercises involving PLA troops.v

 Open-source reporting suggests that the PLA envisions a variety of military functions for commercial ROROs in or 

leading up to conflict, from delivery of forces, to mine emplacement, reconnaissance, and deception.

vi

 

 While the PRC’s MCF and domestic law may provide the PLA with a domestic legal framework to control civilian 

shipping for military purposes, it does not obviate the PLA’s obligations under the LOAC. 

 The veil of domestic legitimacy created by the PRC’s domestic law and regulations sets a dangerous pretext for 

the use of civilian vessels to fulfill belligerent functions in armed conflict, which could increase risk of harm to 

legitimate civilian vessels and crews in future conflicts. 

 Under the LOAC, the principle of “distinction” requires that parties to a conflict distinguish combatants from 

civilians, and military objectives from civilian objects (i.e., protected property or places).vii

 Parties to a conflict may direct force only against combatants / military objectives and must: “(1) take certain 

measures to help ensure that military forces and civilians can be visually distinguished from one another; (2) 

physically separate, as feasible, their military objectives from the civilian population and other protected persons 

and objects; and (3) refrain from the misuse of protected persons and objects to shield military objectives.”viii

 Civilian objects are generally protected from intentional attack or destruction, but may lose that protection and 

be considered military objectives based on their “nature, location, purpose, and use.”ix

 Military objectives are limited to those objects which by their nature, location, purpose or use make an effective 

contribution to military action and whose total or partial destruction, capture or neutralization offers a definite 

military advantage.x

 Civilians enjoy protection from direct attack unless and for such time as they take a direct part in hostilities.

xi

 Those who directly participate in hostilities may be attacked in the same manner as combatants, but lack any of 

the distinct privileges of combatants (e.g., combatant immunity).xii

 States are obligated to take “constant care” to “spare the civilian population, civilians and civilian objects.”

xiii

 The PLA has taken no measures to ensure that ROROs are visually distinguishable from civilian ferries, such as by 

applying gray paint schemes or affixing markings consistent with state practice for military vessels. 

 Likewise, instead of taking “constant care” to mitigate civilian harm and to separate civilians and civilian objects to 

the extent feasible, the PRC has instead instituted domestic law and policy that permits the integration of 

ostensibly civilian platforms into frontline maritime forces. 

 Belligerent acts – e.g. the direct insertion of troops in to conflict – are the province of warships, yet the PLA 

appears intent to use commercial ROROs for more than mere auxiliary / self-defense functions.

xiv

 The civilian façade of ROROs affords the PLA deniability and pretext for accusations of civilian harm when a RORO 

is lawfully attacked in conflict. 

 Commercial ROROs enable the PRC to exploit the law-abidingness of opposing forces that may be apprehensive to

face blowback in the public domain or constrained by policy from attacking vessels that appear civilian in nature.

 In this sense, the PLA’s use of commercial ROROs exploits not only the LOAC principle of distinction, but also the 

LOAC principle of honor and its prohibition on the abuse of the LOAC to gain an advantage over adversaries.xv

2. LOAC Considerations

3. How the PLA’s use of ROROs Abuses the LOAC
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 PRC officials could argue that the LOAC is not controlling in peacetime, and therefore does not constrain the PLA’s 

use of ROROs in military exercises, drills, and other activities outside of armed conflict.

 This argument overlooks the PLA’s apparent intent to use ROROs in armed conflict and fails to appreciate the

interactive dynamic between legal regimes – i.e., a state’s conduct in peacetime is liable to influence how other 

states will respond to like conduct in conflict or how other states will behave in future conflicts.xvi

 Peacetime conduct does not exist in isolation from the LOAC – the efficacy of the LOAC depends on adhering to 

LOAC principles during all military operations, to include ensuring military forces are trained and aware of LOAC 

principles as required by common articles to the Geneva Conventions. xvii

 For this reason among others, U.S. personnel are required by policy to act consistent with the LOAC’s 

fundamental principles and rules in all military operations, including military operations in peacetime.

xviii

 In addition, the United States and many of its allies and partners have established regulations to preserve the

LOAC in peacetime, such as by arming auxiliary vessels only for self-defense.

xix

 PRC officials could also argue that the requirement cited above that non-warships refrain from acts of hostility

pertains only in international armed conflict (IAC) between two or more states, and not to an “internal matter,”

which is how the PRC views Taiwan’s status. 

 This argument may also be refutable because conflict between PRC and Taiwan could bear the characteristics of 

an IAC, to include the presumption that Taiwan will follow LOAC principles much like any state party to a conflict –

it would be paradoxical to hold Taiwan to LOAC principles while the PRC bends the rules. 

 In contrast to the PLA’s conduct, U.S. policy mandates compliance with the LOAC during all armed conflicts, 

however characterized (including non-international armed conflicts).

xx

 ROROs owned by or under the exclusive control of the PLA may be considered auxiliary vessels, which are valid 

military objectives in armed conflict.xxi

 ROROs may also be determined as valid military objectives by their nature, purpose, use, war-sustaining, or warsupporting roles, unless such vessels are innocently employed.xxii

 A vessel is not innocently employed if:

 Persistently refusing to stop upon being duly summoned to do so;

 Actively resisting visit and search or capture;

 Sailing under convoy of enemy warships or enemy military aircraft;

 Armed with systems or weapons beyond that required for self-defense; 

 Incorporated into or assisting in any way, the intelligence system of the enemy’s armed forces;

 Acting in any way as a naval or military auxiliary to an enemy’s armed force; or

 Integrated into the enemy’s war-fighting war-supporting war sustaining effort

 Current intelligence and specific circumstances will inform whether civilian crew onboard a vessel determined to 

be a valid military objective are assessed as direct participants in hostilities or civilians accompanying the force.xxiii

PROPOSED COUNTER-LAWFARE APPROACH

 The PLA incorporates commercial ROROs as key elements of its amphibious invasion force, but takes no measures 

to distinguish these ROROs from civilian ferries, such as by applying gray paint schemes or affixing markings 

consistent with state practice for military vessels. 

 The PLA’s use of commercial ROROs erodes the LOAC principle of distinction by obscuring crucial lines between 

warships and non-warships, civilians and combatants, and civilian objects and military objectives. 

 Upholding the principle of distinction under the LOAC is a legal requirement critical to civilian harm mitigation.

4. Assessment of the PRC’s Potential Legal Positions

5. Targeting Considerations
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Civilian ferry Sheng Sheng 1 off-loading tanks onto semi-submersible barge and 

offshore mobile pier system during August 2020 PLA exercise Eastern 

Transportation-Projection 2020A. 

Source: M. Dahm and C. Kennedy, Civilian Shipping: Ferrying the People’s Liberation 

Army Ashore, CENTER FOR INTERNATIONAL MARITIME SECURITY (9 Sep 21).

The Bang Chui Dao, a 20-year-old civilian passenger Ro-Ro, took part in People’s 

Liberation Army amphibious exercises in August 2020. The vessel, which plies ferry 

routes in northern China across the Yellow Sea and Bohai Gulf, participated in training 

activities off the southern Chinese city of Zhanjiang in Guangdong province.

Source: China Reportedly Converted Civilian Ferries for Military Assault Operations, 

HUMAN EVENTS (17 Aug 21).

Chinese main battle tanks are seen being loaded aboard the commercial RORO ferry 

Zhong Hua Fu Zing. 

Source: J. Seidel, Ominous Sign China is Quietly Preparing to Invade Taiwan, NZ HERALD 

(2 Oct 22).

 The LOAC benefits all of humanity by protecting civilians, but if PLA practice continues to erode distinction such 

that parties to a conflict cannot effectively apply it, civilians will face greater risk of suffering in future conflicts. 

 The PLA abuses the LOAC by leveraging the civilian façade of commercial ROROs to create a veneer of deniability 

and a pretext for accusations of civilian harm.

 The PLA is poised to use commercial ROROs for deterrence by exploiting the law-abidingness of opposing forces 

that may be averse to use force against vessels that appear civilian in character. 

 The PLA’s use of commercial ROROs sets a dangerous precedent that could increase risk of civilian harm not just 

in a conflict over Taiwan, but in other conflicts where civilians may find themselves in harm’s way. 

 Commercial ROROs under PLA control or engaged in war-supporting roles may be the object of a lawful attack by 

an opposing force during armed conflict.

 U.S. policy requires U.S. personnel to act consistent with the LOAC during all military operations, and to comply 

with the LOAC during all armed conflicts however characterized. 

 The international community should expose and condemn the PLA’s use of commercial ROROs to ensure the 

continued efficacy of the LOAC and reduce risk of civilian harm in future conflicts, while also citing it as another 

example of broader intent by the PRC to undermine the current rules-based international order.

GRAPHICS
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ADDITIONAL RESOURCES

Foreign Press

 James Seidel, 2 Oct 2022, Ominous sign China is quietly preparing to invade Taiwan - NZ Herald

 Keoni Everington, 18 Oct 2021, "Video Shows Ship Packed with Chinese Tanks for 'Future Battlefield' in Taiwan," Taiwan

News, https://www.taiwannews.com.tw/en/news/4318076

 Kelvin Chen, 7 Aug 2021, "China Could Use Modified Civilian Ships for Beach Assault on Taiwan," Taiwan

News, https://www.taiwannews.com.tw/en/news/4265916?

U.S. Naval War College/Government

 J. Michael Dahm, January 2023, China Maritime Report No. 25: More Chinese Ferry Tales: China’s Use of Civilian Shipping

in Military Activities, 2021–2022; CMSI China Maritime Report #25: “More Chinese Ferry Tales: China’s Use of Civilian Shipping in 

Military Activities, 2021–2022” | Andrew S. Erickson (andrewerickson.com)

 Lonnie D. Henley, May 2022, China Maritime Report No. 21: Civilian Shipping and Maritime Militia: the Logistics

Backbone of a Taiwan Invasion, digital-commons.usnwc.edu or CMSI China Maritime Report #21: “Civilian Shipping and

Maritime Militia: The Logistics Backbone of a Taiwan Invasion” | Andrew S. Erickson (andrewerickson.com)

 Conor M. Kennedy, Dec 2019, China Maritime Report No. 4: Civil Transport in PLA Power Projection, CMSI China Maritime

Report #4: “Civil Transport in PLA Power Projection” | Andrew S. Erickson (andrewerickson.com) or digitalcommons.usnwc.edu

 J. Michael Dahm, Nov 2021, China Maritime Report No. 16: Chinese Ferry Tales: the PLA's Use of Civilian Shipping in

Support of Over-the-Shore Logistics, CMSI China Maritime Report #16: “Chinese Ferry Tales: The PLA’s Use of Civilian

Shipping in Support of Over-the-Shore Logistics” | Andrew S. Erickson (andrewerickson.com) or digitalcommons.usnwc.edu

 AP, 24 Sep 2022, "China Using Civilian Ships to Enhance Navy Capability, Reach," Voice of

America, https://www.voanews.com/a/china-using-civilian-ships-to-enhance-navy-capability-reach/6761625.html

U.S. Commercial Press

 HI Sutton and Sam LaGrone, 28 Sept 2022, "Chinese Launch Assault Craft From Civilian Car Ferries in Mass Amphibious

Invasion Drill, Satellite Photos Show," USNI News, Chinese Launch Assault Craft from Civilian Car Ferries in Mass

Amphibious Invasion Drill, Satellite Photos Show - USNI News

 David Axe, 27 Jul 2021, "Thousands of Ships, Millions of Troops: China is Assembling a Huge Fleet for War with

Taiwan," Forbes, https://www.forbes.com/sites/davidaxe/2021/07/27/thousands-of-ships-millions-of-troops-china-isassembling-a-huge-assault-flotilla-for-a-possible-attack

 David Axe, 22 Aug 2020, "Surprise! The Chinese Navy Just Transformed this Cargo Ship into an Instant Helicopter

Carrier," Forbes, https://www.forbes.com/sites/davidaxe/2020/08/22/surprise-the-chinese-navy-just-transformed-thiscargo-ship-into-an-instant-helicopter-carrier/

 Thomas Shugart, 16 Aug 2021, "Mind the Gap: How China's Civilian Shipping Could Enable a Taiwan Invasion," War on

the Rocks, https://warontherocks.com/2021/08/mind-the-gap-how-chinas-civilian-shipping-could-enable-a-taiwaninvasion/

 Courtney Mabeus, 26 Jul 2021, "Chinese Navy Using Commercial Car Ferries to Launch Amphibious Landing Craft," USNI

News, Chinese Navy Using Commercial Car Ferries to Launch Amphibious Landing Craft - USNI News

 Mike yeo, 4 Aug 2021, "China Reportedly Converted Civilian Ferries for Amphibious Assault Operations," Center for a

New American Security, China reportedly converted civilian ferries for amphibious assault operations (defensenews.com)

 Conor Kennedy, 16 Jul 2021, "Ramping the Strait: Quick and Dirty Solutions to Boost Amphibious Lift," China Brief Vol 21

Issue

14, https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=&cad=rja&uact=8&ved=2ahUKEwiR592dguv6

AhXqrokEHa-6DRUQFnoECBMQAQ&url=https%3A%2F%2Fjamestown.org%2Fprogram%2Framping-the-strait-quick-anddirty-solutions-to-boost-amphibious-lift%2F&usg=AOvVaw2pSItAf9ZAFRXDMRrCcmXZ

PRC Press/Media

 (U) Zhao Lei, 18 Jun 2015, "New Rules Mean Ships can be used by Military," China

Daily, https://www.chinadaily.com.cn/china/2015-06/18/contact_21036944.htm

 (U) Liu Xuanzun, 25 Jul 2021, "PLA Sea, Land and Air Forces hold Cross-Sea Exercises Amid Taiwan Secessionists

Moves," Global Times, https://www.globaltimes.cn/page/202107/1229616.shtml
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i

See What-is-MCF-One-Pager.pdf (state.gov)

ii Crossing the Strait: China’s Military Prepares for War with Taiwan, NATIONAL DEFENSE UNIVERSITY (2022).

iii See press release: Explaining and Clarifying the Matter Regarding the Media Coverage of ‘60 Micro-Class Missile Assault Boats 

Reduced from the Initially Recorded $1.67 Billion to Merely $1.04 Million, MINISTRY OF NATIONAL DEFENSE (2 Sep 19).

iv See “Helping Civilian Ships Joint the Army,” http://tv.cctv.com/2019/05/14/VIDEciAU5Xo9SVOQVYhz8zht190514.shtml; see also J. 

Seidel, Ominous Sign China is Quietly Preparing to Invade Taiwan, NZ HERALD (2 Oct 22).

v

J. Michael Dahm, More Chinese Ferry Tales: China’s Use of Civilian Shipping in Military Activities, 2021–2022, China Maritime Report

No. 25, U.S. NAVAL WAR COLLEGE (January 2023).

vi Lonnie D. Henley, Civilian Shipping and Maritime Militia: The Logistics Backbone of a Taiwan Invasion, China Maritime Report No. 

21, U.S. NAVAL WAR COLLEGE, 5-6 (May 2022). 

vii Protocol Additional to the Geneva Conventions of 12 August 1949 [hereinafter AP I], at art. 48 and 52. Although the United States 

is not a party to AP I, it does accept the majority of AP I’s provisions as customary international law. See also DOD LAW OF WAR 

MANUAL, at § 2.5. 

viii DOD LAW OF WAR MANUAL, at § 2.5.3.

ix AP I, at art. 52(2); see also DOD LAW OF WAR MANUAL, at § 5.6.3. 

x AP I, at art. 52(2); see also San Remo Manual on International Law Applicable to Armed Conflicts at Sea, art. 60 (1994) [hereafter 

San Remo Manual]

xi Id., at art. 51(3).

xii DOD LAW OF WAR MANUAL, at § 5.8.

xiii Article 57 of Additional Protocol (AP) 1. The United States is not a party to AP 1, but considers many of its provisions binding 

customary international law. 

xiv See e.g., The Oxford Manual of the Laws of Naval War (1913) (prohibiting non-warships from conducting “acts of hostility”); see 

also, German Law of Armed Conflict Manual, p 145 (2013), (“The following vessels and persons may not perform acts of naval 

warfare: state ships other than warships, even when carrying out support services for the naval forces; merchant ships; fishing 

vessels and other civilian ships; prize crews of captured ships; state aircraft other than military aircraft; and civilian aircraft.”)

xv DOD LAW OF WAR MANUAL, at § 2.6 and Article 37, Additional Protocol I. Honor is sometimes called chivalry and is based on notions 

of trust, good faith, justice, and professionalism. The concept of chivalry informs the LOAC’s express prohibition of treachery and 

perfidy, defined as “bad faith.” 

xvi For discussion on the “interactive dynamic” see Law of Naval Warfare, Stephens & Stubbs, Chapter 15 (Non-Traditional Vessels, 

Tim Boyle) LexisNexis Australia; 1st edition (7 October 2019)

xvii Nations are required to “include the study [of the law of armed conflict] in their programmes of military . . . instruction, so that 

the principles thereof may become known to all their armed forces.” See Common Articles 47, 48, 127, 144 to the Geneva 

Conventions. 

xviii DODD 2311.01, Department of Defense Law of War Program

xix Leading navies typically arm auxiliaries only for defensive purposes. See generally, S Saunders, Jane’s Fighting Ships 2018–2019, 

118th ed, IHS, Coulsdon, 2018; see also E Wertheim, The Naval Institute Guide to Combat Fleets of the World, 16th ed, Naval 

Institute Press, Annapolis, 2016.

xx DODD 2311.01, Department of Defense Law of War Program

xxi Warships are those that bear external markings of such class of ship, under the command of an officer, “and manned by a crew 

which is under regular armed forces discipline.” Auxiliary vessels normally fulfill supporting roles (unable to commit belligerent acts), 

are not warships, but are “owned by or under the exclusive control of the armed forces of a State and used for the time being on 

government non-commercial service. Importantly, auxiliary vessels may be considered military objectives and targeted during 

conflict, the same as a warship. See San Remo Manual at art. 13(g), 13(h), 60(b).

xxii See San Remo Manual Art 59-66; see also U.S. Commander’s Handbook on the Law of Naval Operations (NWP 1-14), Section 8.6

xxiii This assessment may be relevant for LOAC proportionality assessments and combatant immunity / prisoner of war status.