Manila Port Disruption: Why Empty Returns Matter for D&D

Customs brokers and truckers at the Port of Manila began a voluntary work stoppage on October 5, and a second trucking group starts a three-day transport holiday on October 6. For importers with containers already discharged at the Manila International Container Port (MICP) or Manila South Harbor, the published carrier Demurrage & Detention tariff clock does not automatically stop because of the stoppage.

At carriers that bill a combined import charge in the Philippines, including Maersk and OOCL, one clock runs from discharge to the day the empty is accepted at the depot. A release held up this week and an empty sitting on a chassis waiting for depot space can therefore add days to the same charge. The draft relief being developed in Manila makes the underlying timestamps unusually important: when the consignee requested a return location, when the carrier responded, whether a yard was assigned, and whether that yard actually accepted the box.

What the Stoppage Covers

The broker-led rest day. The Practicing Customs Brokers Association of the Philippines Inc. (PCBAPI) began a voluntary “digital protest and rest day” on October 5, after postponing it from September 28. The action was planned to run for about a week. Participating brokers and importers were asked to limit import processing. Truckers supporting the action were asked not to accept gate passes, book truck manifests or dispatch trucks for affected shipments. Organizers said the action does not shut down the ports.

The truckers’ transport holiday. The Confederation of Truckers Association of the Philippines (CTAP) is suspending trips for three days from Tuesday, October 6, citing fuel costs and empty-container handling. CTAP’s president has said shipping lines impose detention even when truckers cannot return containers because no space is available.

Participation is partial. The Alliance of Concerned Truck Owners and Organizations (ACTOO), reported to represent roughly 60 percent of port-based truckers, said it would not join. Whether a given container moves this week therefore depends partly on which broker and trucker are handling it.

The dispute centers on Manila’s empty-container backlog and limited depot capacity. Hapag-Lloyd has separately suspended new bookings to Manila, Batangas and Subic Bay through December 31, citing continued congestion and severe constraints on depot and empty-container return capacity. PCBAPI’s chair says carriers can take two weeks to a month to accept returned empties, and truckers at a September 23 industry forum described waiting up to two weeks for a depot to take a box. In a letter reported by The Loadstar, the Bureau of Customs (BOC) commissioner told the Port of Manila to act on the backlog and suggested moving boxes that had waited more than 10 days offsite. The BOC has also warned that the work stoppage could aggravate congestion.

One Clock From Discharge to Empty Return

Many carriers split the charge in two: demurrage while a full container sits inside the terminal, and detention from gate-out until the empty comes back. In the Philippines, Maersk and OOCL each publish a single combined import charge. A delayed release uses up free time at the terminal end, and a refused empty return extends the count at the other end, so both stages of this week’s disruption can land on one bill.

Carrier	Clock starts	Clock ends	Free time	40′ dry charge after free time (PHP per day)
Maersk	Discharge day, counted as day 1	Empty gate-in at depot, counted	8 days	4,000 (days 9 to 14), 5,000 (days 15 to 19), 6,000 (day 20 onward)
OOCL	00:00 on the first calendar day after discharge	Day of empty gate-in	8 calendar days, weekends and Philippine holidays included	2,500 (first 3 chargeable days), then 5,000

Combined import D&D for the Philippines, 40′ dry container. Maersk: tariff revision effective from price calculation date 5 July 2024. OOCL: Philippines D&D page, maximum rates, viewed October 6, 2026.

Both carriers allow eight free days, but they start counting on different days. Maersk counts the discharge day itself as day 1. OOCL starts at midnight the day after discharge. For two containers discharged on the same date, Maersk’s chargeable days therefore begin one calendar day earlier. Maersk also states that its combined tariff is subject to terminal storage and other surcharges.

A worked example

Take a 40′ dry Maersk container discharged at MICP on Friday, October 2. Day 8 falls on October 9, so charges start on October 10. Suppose the broker holds release processing through the PCBAPI week, the box is picked up around October 12, and the empty then waits two weeks for depot acceptance before its gate-in on October 26. That is day 25 on the clock. The combined charge comes to PHP 85,000 on one box: 6 days at PHP 4,000, 5 days at PHP 5,000 and 6 days at PHP 6,000. Terminal storage, where it applies, comes on top. Every additional day at either end can therefore increase the combined charge.

The Draft Rule That Turns on Timestamps

The BOC has been developing a Joint Administrative Order (JAO) on yard utilization and transparency in local charges. The publicly posted consultation draft dates from July 2026, but the BOC said subsequent revisions incorporated stakeholder comments. As of October 5, the agency was still describing the JAO as under development, so the provisions below should be treated as proposed rather than final.

Section 31.2 would bar D&D charges when the failure to return a container is attributable to the shipping line. The public draft gives examples of shipping-line fault, including failure to acknowledge a request for a return location within 24 hours or failure to assign a container yard or terminal within 48 hours of the request.

Section 18.1.1 applies once the importer shows the goods were stripped and delivered. The line then has 24 hours to confirm an available yard. If it does not confirm, or the yard rejects the box for lack of space, the BOC designates another yard. Under the draft, the line cannot charge detention in that situation and bears the re-routing cost.

Section 31.2 nevertheless says D&D may still be imposed where the consignee failed to notify the shipping line within the applicable free time. A team that first asks where to return an empty only after free time has expired may therefore lose the protection contemplated by that provision, even if the depot later turns the truck away. The draft focuses on shipping-line responsibility for the return process. Delay caused by a terminal is a separate question, which we covered in how US and Brazilian regulators treat demurrage when the terminal caused the delay.

The draft also describes a BOC-run automated monitoring system for container movements and status. Operationally, that reinforces the value of keeping a complete event history around discharge, delivery, return-location requests, carrier responses, depot assignments, rejection and eventual empty return. The Association of International Shipping Lines has previously questioned whether the BOC has statutory authority to regulate international carriers’ commercial charges. It later said it supported regulation of local charges through the JAO, provided the final rules include appropriate safeguards. Whether any final order would face a legal challenge will depend on its final text.

If your team is rebuilding discharge, gate-out and empty-return dates from carrier portals one container at a time, walk through how ops teams keep a timestamped event history for every container across carriers.

What to Check on Manila Containers This Week

Carrier D&D structure. For every container discharged at MICP or South Harbor since late September, note whether the carrier bills a combined import charge or separate demurrage and detention.
Last free day. Recompute it per carrier using that carrier’s own counting rule. Maersk and OOCL start the count on different days.
Broker and trucker status. Ask directly whether they are joining the PCBAPI rest day or the CTAP transport holiday. ACTOO said its truckers would not take part.
Return-location requests. Send them in writing before free time ends. Keep the timestamp of the carrier’s reply, or a record that no reply came within 24 hours.
Delivery and rejection records. Keep proof of delivery and stripping for each container, plus any depot rejection notice. Under the public draft JAO, these records may be important in establishing whether the return delay was attributable to the carrier or an assigned yard.
Containers still at sea. Check the ETA and prepare release documents before arrival, so that a stoppage running longer than planned does not consume free time ahead of pickup.

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