FMC rule · 46 CFR 541
Late or incomplete demurrage and detention invoices don't have to be paid.
We check your D&D invoices against the federal rule for free. You pay 30% of what gets cancelled or refunded, and nothing otherwise.
- Container
- ABCU 214508 3
- Port of discharge
- Long Beach, CA
- Free time
- 4 days · Jan 27–30
- Days charged
- Jan 31–Feb 4 · 5 days
- Empty returned
- Feb 4, 2026
- Invoice date
- Mar 14, 2026
- Tariff rule
- missing · §541.6(c)(2)
- Certifications
- missing · §541.6(e)
- Total due
- $1,250.00
Issued 38 days after charges stopped. Under §541.7 the billed party is not required to pay.
- 30 daysfor the carrier to issue the invoice after charges stop §541.7
- 20 itemsof required details listed in the rule. Miss one and the charge isn't owed §541.5–6
- $0you pay us if nothing is cancelled or refunded
What makes an invoice not payable
Two things we check on every invoice.
It was sent late
Carriers and terminals have 30 calendar days from the last day of charges to issue the invoice. After that, the charge isn't owed.
It's missing required details
Leaving out any one of these removes the obligation to pay:
- B/L and container numbers (a)
- Why you're the party billed (a)(4)
- Free time, with start and end dates (b)
- Container availability date (b)(6)
- Exact dates charged (b)(8)
- Tariff or contract rule and rate (c)
- Dispute contact and instructions (d)
- Two carrier certifications (e)
The rule's "who may be billed" section (§541.4) was set aside by a federal court in 2025. We don't rely on it. Full checklist and sources
How it works
You send invoices. We do the checking and the paperwork.
- 01
Send your invoices
PDFs or portal screenshots from the last few months.
- 02
We check every line
Dates, required fields and rates, against Part 541. You get a written result.
- 03
You send the dispute
We draft the letter for each charge. You send it in your company's name.
Pricing
The check is free. We take 30% of charges that are cancelled or refunded. If nothing is, you owe nothing.
No retainer, no subscription.
FAQ
Questions
Which invoices does the rule cover?
Demurrage, detention and per diem invoices from ocean carriers, marine terminal operators and NVOCCs, in effect since May 28, 2024. Online portal statements count. Trucker invoices aren't covered directly, but the carrier invoice behind them is.
I already paid. Is it too late?
Not necessarily. You can ask the carrier for a refund, and it must attempt to resolve the request within 30 days (§541.8). You can also file a charge complaint with the FMC. We draft either one.
Are you a law firm?
No. We audit invoices and prepare dispute letters. You send them in your own name.
What do you need from me?
The invoices. Bills of lading and gate-out or empty-return dates help us check timing.
What if nothing is wrong?
Then you know your invoices are in order, and you owe nothing.
Free invoice check
Send us a few invoices.
One or two recent ones is enough to start. Redact prices if you like.
Prefer email? hello@demurragerefund.com