Recovery OS Guide

Demurrage & Detention Invoice Review

A current, evidence-first U.S. ocean D&D review guide based on Federal Maritime Commission requirements.

Regulatory update: In September 2025, the D.C. Circuit set aside 46 C.F.R. §541.4. The FMC states the rest of Part 541 remains in effect, including invoice-information and timing requirements.

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

Screen a synthetic D&D evidence gap.Open the Recovery Scan