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The Federal Maritime Commission's (FMC) Final Rule on Detention and Demurrage Billing Requirements, effective May 28, 2024, mandates significant adjustments in how ocean carriers and terminal operators handle demurrage billing.


To ensure compliance and maintain seamless operations, Atlantic Pacific Tariffs, Inc., the 5th largest tariff publisher for NVOCCs in the world, compiled a detailed guide tailored for Non-Vessel Operating Common Carriers (NVOCCs) and Vessel Operating Common Carriers (VOCCs): 

Immediate Steps for Compliance: 

1. Review Current Billing Processes:

- Assess your existing billing procedures to comport with the new FMC requirements.

- Identify gaps, especially in to whom invoices are issued.

2. Update Contractual Agreements: 

- If you are an NVOCC, ensure that your NRAs or NSAs with shippers specify that demurrage and detention charges will be treated as pass-through charges unless you opt to publish your own charges as set forth in your governing tariff.

- If you are a VOCC, ensure your service contracts with shippers specify responsibilities for demurrage and detention charges are in sync with the new rule.

- Clarify invoicing parties to avoid conflicts.

3. Train Your Staff:

- Conduct training sessions for your billing and customer service teams on the new requirements.

- Focus on the importance of timely invoicing and the specifics that need to be included in each invoice.

- AP Tariffs offers customers free training sessions. Please click here to schedule a follow-up meeting to discuss how these changes will impact your NVOCC operations.

4. Implement a Dispute Resolution Process:

- Establish a clear process for handling disputes regarding demurrage and detention charges.

- Ensure this process allows for resolution within the 30-day timeframe mandated by the FMC.


Timeline and Specific Actions: 

Before May 28, 2024:

- Complete internal reviews and training. 

- Update all contracts and service agreements to reflect the new invoicing requirements.

By May 28, 2024:

- Fully integrate the new billing and dispute resolution processes into your operations. 

- Communicate changes to your shippers, consignees, and truckers, emphasizing the importance of the 30-day dispute window.

For NVOCCs Specifically:

- Understand Your Position: As both a billed and billing party, NVOCCs have an extended 30-day period, on top of the initial 30 days, to dispute charges with VOCCs. This takes into account the role intermediaries as NVOCCs play.

- Coordinate with VOCCs: Establish clear communication channels with VOCCs from whom you receive invoices. This will ensure you can manage disputes effectively within the extended timeline should your client dispute an invoice for demurrage and/or detention charges.

For VOCCs Specifically:

- Clarity in Invoicing: As primary carriers, VOCCs must ensure invoices are issued directly to the party responsible for the charge, either the shipper or the consignee, based on the contractual agreement.

- Timely Communication: VOCCs are required to issue invoices within the 30-day period post-charge accrual to comply with the FMC regulations.

Ongoing Compliance:

- Monitor and Adjust: Regularly review your billing and dispute processes to ensure they comply with FMC regulations.

- Stay Informed: Keep abreast of any further regulatory changes by the FMC that may affect detention and demurrage billing practices. 

Adhering to these guidelines will ensure compliance with the FMC's final rule and foster a more transparent, efficient, and equitable operational environment for NVOCCs, VOCCs, and their clients.


Remember, a proactive approach to compliance can significantly reduce the risk of disputes and strengthen your relationships within the industry.


Contact Us Now!

AP Tariffs is your best partner in the business, ensuring you stay on top of the FMC rules and regulations. Email us at or schedule a free consultation (Spanish, Mandarin and Korean languages also available).

FMC Registration Webinar on March 27, 2024

Atlantic Pacific Tariffs, Inc. (AP Tariffs) is excited to announce it will be presenting at the upcoming WCAworld Academy webinar on US FMC Registration Requirements.

Join us to navigate through the legal requirements for ocean shipping to/from the USA, with in-depth discussions on the latest updates and compliance practices.


  • English version: Wednesday, 27 March 2024, at 12 PM EST

  • Chinese version: Thursday, 28 March 2024, at 9 PM EST

Don't miss this opportunity to stay ahead in the maritime logistics industry! Remember, you must be a WCA member to join.

AP Tariffs has top-notch technology, excellent problem-solving skills, and a responsive support team to help your business grow in compliance with FMC regulations.

Not a WCA member? Schedule an online meeting with us, Please Click Here.  You can also e-mail your queries to

AP Tariffs Helps NVOCC with FMC Registration
FMC Registration with AP Tariffs

Atlantic Pacific Tariffs, Inc. (AP Tariffs) representatives will be in Dubai from February 27 to March 2, 2024, to attend the WCA's 13th Annual Conference, dubbed as the world's largest freight forwarding event.


About 4,500 delegates from over 180 countries are expected to attend, providing exciting opportunities in the largest logistics networking conference to be ever held.


Engage with AP Tariffs!


AP Tariffs, the 5th largest tariff publisher for NVOCCs in the world, is one of the sponsors of the WIS Fine Wine Event happening on Feb. 29, Thursday, from 17:15 to 19:30 in the Al Multaqua Ballroom (ground floor) of the Dubai World Trade Center.


AP Tariffs' President Mauricio Larenas will be present at the five-day event and will be more than happy to discuss issues related to registration with the U.S. Federal Maritime Commission (FMC), a crucial topic for WCA members worldwide.


Navigating Regulatory Requirements


The U.S. FMC regulates Ocean Transportation from and to USA Territories. Non-Vessel Operators Common Carriers (NVOCCs) conducting ocean transportation operations touching USA territories must obtain an Organization Registration from the FMC.


For WCA members engaged in international trade, obtaining FMC registration is essential for ensuring regulatory compliance and facilitating smooth operations.


Guidance for WCA Members


Amidst evolving regulatory landscapes and heightened scrutiny, AP Tariffs can provide WCA members with invaluable guidance on navigating FMC registration requirements -- from understanding documentation protocols to fulfilling financial responsibility obligations.


Unlocking Trade Opportunities: Leveraging FMC Registration


FMC registration unlocks a myriad of trade opportunities for WCA members, empowering them to expand their reach and access lucrative markets with confidence. By obtaining FMC registration, WCA members demonstrate their commitment to transparency, accountability, and professionalism, enhancing their credibility and competitiveness in the global marketplace.


Facilitating Business Growth: Fostering Trust and Reliability


FMC registration serves as a testament to the reliability and trustworthiness of WCA members, instilling confidence in customers and partners alike. With FMC registration, WCA members signal their adherence to industry best practices and regulatory standards, paving the way for sustainable business growth and long-term success.


Building Strategic Partnerships: AP Tariffs Is Your Best Partner!


AP Tariffs will make your FMC registration experience fast and easy.

  • We offer WCA members a simplified, cost-effective one-stop solution.

  • We have experts available to address your concerns

  • We can obtain FMC, AMS/ISF Approval in 2 to 4 weeks


AP Tariffs is ready to help your business grow. We have the top-notch technology, excellent problem-solving skills, and a responsive support team that will keep you compliant with FMC rules and regulations.


If you are attending the WCA Conference in Dubai, send us an e-mail. We would love to talk to you in person.


For online meetings, Please Click Here

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