After the invoice · testing a demurrage bill · read 07/26–07/30/2026
A demurrage invoice has rules, and this is how to test whether yours meets them
- A demurrage invoice in US trade is governed by 46 CFR Part 541, the rule that took effect on 05/28/2024. Read the CFR text rather than any summary of it, including this one: the rule has been before the D.C. Circuit twice since, and one decision changed who may be billed.
- Demurrage disputes are filed with the carrier, not with the regulator, and every major line publishes its own procedure. The common shape: in writing, within 30 calendar days of the invoice date, quoting the invoice number, the container number, the bill of lading number and proof of the error.
- Demurrage and detention run on two different thirty-day clocks and the market blurs them. One limits how long the biller has to issue the invoice. The other limits how long you have to contest it. Missing the second is the mistake that costs money.
- Demurrage is billed by the ocean carrier and terminal storage by the terminal, and one statement can carry both for the same days. Establish which of the two you are looking at before disputing an amount, because they answer to different documents.
What a demurrage invoice is, and what it is not
A demurrage invoice is a bill from your ocean carrier for days your container spent inside the terminal after its free time ran out. It is not a fine, it is not discretionary, and it is not the same document as the terminal’s storage invoice — which can arrive separately, from a party you never contracted with, for some of the same days.
What it is above all is a document with requirements. In US trade a demurrage or detention invoice has to meet a federal rule, and the practical question is not whether the charge feels fair but whether the paper meets the rule. How the clock behind it runs: how the demurrage clock runs.
Who issues each line, and who owes it
An invoice for a container that sat can carry lines from three different parties, and only the first of them is the carrier you booked with.
How this page is built · what we are paid
- Every rate on this page is read from a carrier’s own US import tariff, with the date we read it.
- What carriers require of a dispute is read from their own published procedures — eight of them — and is labelled as their procedure rather than as law.
- The federal rule is linked rather than summarised. Its conditions are not recited here, and §“the hole” says exactly why.
- No carrier, port or terminal has paid to appear here, and no link on this site is a referral link.
| Charge | Billed by | Owed by | Where the box is | Amount |
|---|---|---|---|---|
| Demurrage | Ocean carrier | Consignee or the counterparty named on the invoice, not both | inside the terminal, past the carrier’s free time | $125–$390 first paid day8 of 9 tariffs · read 07/28–07/29/2026 |
| Terminal storage | Marine terminal operator | Cargo interest | inside the terminal, past the terminal’s own free time | not checked yetgap A |
| Detention, or per diem | Ocean carrier | Whoever holds the box outside the gate | outside the gate | $170–$250 per daycarrier tariffs · read 07/28–07/29/2026 |
| Chassis per diem | Chassis pool or carrier | Motor carrier, passed through to you | wherever the chassis is | not checked yetgap G — what the chassis adds to the bill |
What the days actually cost while the dispute runs
The days keep counting while a dispute runs, and knowing what they cost is the difference between holding a position and paying interest on it.
| Line | Per day | What moves it |
|---|---|---|
| First paid day of demurrage | $125–$3908 of 9 tariffs · read 07/28–07/29/2026 | the carrier, then the terminal your service called at |
| Later tiers | up to $1,000 from day 30HMM at New York · read 07/29/2026 | the ceiling of everything we read; tiers step up in every tariff |
| Detention outside the gate | $170–$250carrier tariffs · read 07/28–07/29/2026 | starts when the box leaves, not when demurrage stops |
| Terminal storage for the same days | not checked yetgap A — about 80 tariffs unread | a separate invoice, on its own clock |
What each of the nine carriers charges after free time, tariff by tariff: what each ocean carrier charges after free time.
The rule your invoice answers to, and why you should read it yourself
A demurrage or detention invoice issued in US trade answers to a Federal Maritime Commission rule codified as 46 CFR Part 541, in force since 05/28/2024 and published at 89 FR 14330. That much is settled and citable.
What is not settled is any summary of it, including the one this site used to carry. The rule has been before the D.C. Circuit twice: a decision of 09/29/2025 reshaped billing for motor carriers, and a separate decision upholding the Commission against Evergreen on detention was reported 07/08/2026. One of those touched the provision about who may be billed — which is exactly the part every summary quotes.
So this page links the text instead of reciting it: 46 CFR Part 541 on eCFR. Read the version in force on your invoice date. That is a weaker-looking answer than the four numbered conditions everyone else prints, and it is the one that will still be true next quarter.
89 FR 14330 of 02/26/2024 · D.C. Circuit 09/29/2025 · reported 07/08/2026 · read 07/26–07/30/2026. Descriptive, not legal advice.
What to do, in order, before you pay anything
Before paying anything, test the paper. These steps are what the carriers’ own published dispute procedures require — read from eight of them — rather than what the federal rule says, and they are in the order that protects your position.
- Establish who issued it. Carrier or terminal. The dispute goes to whoever wrote the document the charge came from, and sending it to the wrong party costs days you are being charged for.
- Get the tariff the rate came from. The rate, the tier structure and the free-time definition are in a public document. If the invoice does not name it, ask for the name and the effective date.
- Rebuild the count yourself. Discharge date, the hour the clock starts, free days, the convention — calendar or working — and the tier the days fall into. Most disagreements are about which day was day one.
- Check what the invoice does not say. Container number, the dates charged, the rate applied, the tariff it comes from, and how to dispute it. Note every element that is missing rather than arguing the amount.
- Dispute in writing, quickly, with the numbers attached. The published carrier procedures we read ask for a written request within 30 calendar days of the invoice date, carrying the invoice, container and bill of lading numbers plus evidence of the error. That is their procedure, not the federal rule.
- Keep the days from growing while you argue. The charge accrues during a dispute. Move the box or book the appointment even where you are confident the bill is wrong — what to do when the box will not move.
How many free days each carrier gives, which is where most rebuilt counts go wrong: how many free days each port allows.
Where this does not apply
This page does not apply in four situations, and one of them is a different subject that arrives here by accident.
- The charge is the terminal’s storage, not the carrier’s demurrage. Different biller, different document, and the federal rule is written about demurrage and detention.
- The delay was a port omission or a rollover. Then the question is whose schedule failed, not whether the count was right — when the ship skips your port.
- The invoice is for detention outside the gate. The clock, the tariff line and the tier are different from demurrage even though the carrier and the format are the same.
- You are looking for a credit-report dispute letter. Those arrive on this subject through the words “dispute letter” and belong to a different law entirely; nothing on this page applies to them.
The market is quoting a 2024 announcement about a rule that has since been to court
The market answers this question by quoting a February 2024 announcement about a rule that has since been to court twice. These are our own counts across the five queries this page answers.
| What we measured | Value |
|---|---|
| Top-ten addresses across the five queries | 43 |
| How many carry a date | 23 — the other 20 carry none |
| Dated inside 2024, the year of the announcement | 11 |
| Dated after the D.C. Circuit decision of 09/29/2025 | one |
| Carrier procedure pages with no date at all | 8 — the documents people follow |
| Where the federal text itself ranks | position 3 — above almost every summary of it |
our own capture of the five dispute queries, Google US, 07/26/2026
The quick answer on “is my demurrage invoice valid” responds with free-time durations, which answers a different question. That is the gap this page is written into.
The status system behind every figure here, and the corrections log — which carries the entry where this recitation was removed: how every figure here is sourced.
- Not legal advice. A description of a federal rule is a description of it, and the rule as in force on your date governs.
- Not a quote. The tariff and the bill of lading in your own file decide what you owe, not a number on this page.
- Not a filing service. We do not act for you, contact your carrier, or take a share of anything recovered.
Questions about testing and disputing an invoice
Is my demurrage invoice valid?
Test it against three documents: the carrier tariff in force on your dates, the terminal tariff if terminal storage is on the same statement, and 46 CFR Part 541. The step list above is the order to do it in. Position zero currently answers this query with free-time durations, which is a different question.
Can I dispute a demurrage invoice?
Yes, and it goes to the carrier rather than to the regulator. Every major line publishes a procedure: in writing, within 30 calendar days of the invoice date, quoting the invoice, container and bill of lading numbers and the proof of error.
What are valid reasons to dispute a charge?
An error in the dates charged, in the rate applied, in the tariff amendment used, or in the party billed. A dispute about the level of a published rate is not a billing dispute — that is a tariff question and it goes somewhere else.
Who is responsible for demurrage charges?
The party the invoice names. The table above sets out all four lines a statement can carry, who issues each and who owes it, because demurrage, detention, terminal storage and chassis per diem do not share a biller.
How do I write a demurrage dispute letter?
In writing, inside the carrier's window, with the invoice number, the container number, the bill of lading number and evidence of the error — discharge time, gate-out time, the tariff page the rate comes from. Use the carrier's own published route; a letter sent elsewhere does not stop the clock.
Can I negotiate demurrage charges?
This is a procedure with a deadline rather than a negotiation. You submit a documented dispute inside the carrier's window and the carrier answers it. Framing it as a negotiation is what causes people to miss the window.
How long do I have to dispute?
Thirty calendar days from the invoice date under the procedures the carriers publish. That is not the same thirty days that limits how long the biller had to issue the invoice — two clocks, two directions, and the market routinely blurs them.
Are 609 or 623 dispute letters relevant to a demurrage invoice?
No. Sections 609 and 623 belong to the Fair Credit Reporting Act and concern credit reports. Google pulls those templates into this subject on the words dispute letter alone. They have nothing to do with ocean freight, and a demurrage dispute follows the carrier's published procedure instead.
Before the invoice, the question is how the clock runs and how to keep it from starting. After it, the question is whether the document meets its requirements. Both pages are linked above, and the boundary between them is deliberate.