Anatomy of a demurrage invoice
$4,410 billed. Up to $4,410 recoverable. Here is a representative US-import demurrage invoice, run through the DemurrageGuard engine and taken apart against the Federal Maritime Commission billing rule (46 CFR part 541).
This is an illustrative worked example, not a client case. The invoice is built from the defects that turn up most often; the recovery figures are the engine's exact output applying the rule, not estimates.
Most US importers pay demurrage and detention invoices without checking them — because checking one properly means knowing the FMC billing rule and doing the math by hand. I built an engine that does it in seconds. Here is what it finds.
What the audit found — four things, all citable
The invoice was issued 41 days after the charge was last incurred. The rule gives the billing party 30 calendar days — miss that, and the billed party is not required to pay the charge. That alone puts the whole $4,410 in play.
Two mandatory elements were absent: the basis for why the billed party is the proper party of interest, and the digital means to dispute. Under §541.5, omitting required information eliminates the obligation to pay.
Five of the billed days should never have run — three terminal-closure days and two with no truck appointment available. The correct charge is $2,835, not $4,410 — $1,575 over-billed before the two fatal defects above.
One day left to request mitigation, refund, or waiver. A recovery this clean is lost entirely if you miss that date — and nobody is watching it by hand.
The floor is the over-billing you can prove with gate logs and appointment records. The ceiling is the entire invoice, because untimeliness (§541.7) and missing content (§541.5–§541.6) each independently void the obligation to pay.
The letter, drafted automatically
We formally dispute the demurrage charge and request mitigation, refund, or waiver on the following grounds: • Untimeliness (46 CFR §541.7): issued 41 days after the last charge (limit 30). A late invoice need not be paid. • Content deficiency (§541.6): two required elements missing. Under §541.5, omitting required information eliminates the obligation to pay. • Free-time tolling: five days should not be chargeable. • Recalculation: the correct charge is $2,835, not $4,410. On this basis we consider up to $4,410 to be improperly billed …
Why this matters
This is one invoice. A mid-size importer receives dozens a month, and the defects above are common, not exotic: late invoices, missing content, and free time that kept running through closures and appointment gaps. The FMC rule is a legal lever, not a negotiation — but only if someone checks every invoice against it before the clock runs out.
I'm Abhiram— MBA in Supply Chain & Global Operations (Middlesex University Dubai). I do this for a living, under DemurrageGuard: audit your US D&D invoices against the FMC rule, quantify what's disputable, and draft the letter. You pay 25% of what's actually recovered — nothing if nothing comes back.
Decision support, not legal advice. Rule sections cited so your counsel can verify; §541.4 (“properly issued invoices”) was vacated by the D.C. Circuit. Figures are the engine's output on an illustrative example.