Why D&D deserves a separate review lane
The FMC reports that nine monitored ocean carriers collected roughly $15.4 billion in detention and demurrage charges from April 2020 through March 2025. D&D therefore warrants its own evidence model rather than being treated as a generic accessorial.
Timing and invoice-content checks
The FMC states that the remaining rule includes a 30-day invoice issuance deadline and requirements for accurate and sufficient invoice information. Missing required information can affect the billed party’s obligation to pay. Recovery OS should flag missing evidence for review rather than automatically declaring a charge invalid.
Evidence fields worth preserving
Container identifiers, free-time dates, event dates, applicable rate/rule references, invoice issuance date and mitigation/refund/waiver process information are useful review inputs. The public lab currently treats missing D&D dates as an evidence gap, not an eligibility conclusion.
Authoritative sources
FMC: 2025 court decision and remaining rule
FMC: detention and demurrage data
FMC: final rule effective-date guidance