Stop Paying For Idle Boxes: A Q4 Detention And Demurrage Playbook For LSPs

Detention and demurrage billing rules tightened in 2024, but preventable charges still drain margin in Q4. This playbook shows brokers, forwarders, and BCO import teams how to fix invoice hygiene, manage last free day risk, and write quotes that survive disputes. We anchor the guidance in the Federal Maritime Commission’s 2024 billing rule and its incentive principle so your teams can defend every dollar with documentation.

What Changed In The Rules

FMC billing rule in force. As of May 28, 2024, detention and demurrage invoices must include required data elements, be billed to the correct party, and meet strict timelines for issuing, disputing, and resolving. Non compliant invoices risk enforcement.
Incentive principle still applies. The FMC’s interpretive rule focuses on whether charges incentivize fluidity. If port or carrier conditions block pickup or return, invoices face heightened scrutiny.

What Still Costs You In Q4

Clock management failures. Last free day not surfaced early, weekend cutoffs missed, or appointments booked after free time expires.
Party and document mismatches. Bill of lading parties misaligned with who has the ability to move the box. Wrong consignee on invoices invites disputes that drag on.
Opaque quotes. Hub or yard dwell hidden inside transit time. Customers challenge charges because your variability was never disclosed.

Five Levers You Can Pull This Week

1) Make last free day visible by default

Expose last free day and free time type on every shipment page and milestone email. Update automatically when ETA or availability moves.
Trigger alerts at T minus 72 hours and T minus 24 hours with a named action owner.

2) Set appointment and doc SLAs that match the rule

Cutoff to request first appointment no later than T minus 48 hours from last free day.
Two hour SLA to clear holds and pay release once availability posts. Document carrier or terminal system outages as evidence.

3) Quote with transparent dwell bands

List terminal dwell as a separate band rather than hiding it inside ocean time. Example: “Berth to availability typically 24 to 72 hours at Terminal X.”
State the governance: when published yard utilization or turn times exceed a threshold for two consecutive weeks, increase the band by one day and notify customers.

4) Align the billed party with the ability to perform

Match your service terms to who controls pickup or return. If you hold the trucking leg, expect invoices in your name and flow them through your dispute SOP.
If the shipper controls drayage, require that invoices go to the shipper and include their reference IDs on the BL and delivery order.

5) Dispute with evidence, not opinion

Attach time stamped screenshots of terminal advisories, appointment rejections, and system outages.
Cite the incentive principle when access was blocked. Include your attempt timestamps so the causal chain is clear.

Templates You Can Paste Into Quotes

Free time and last free day disclosure
“Free time quoted as [X] working days at destination terminal. Last free day is surfaced on the shipment record and alerted at 72 and 24 hours before expiry. If terminal access is unavailable, we document and dispute per FMC standards.”

Terminal dwell band
“Berth to availability at [Terminal] usually ranges 24 to 72 hours. When published yard utilization or truck turn time exceeds our threshold for two consecutive weeks, we increase the dwell band by one day and notify you.”

Billed party alignment
“Detention and demurrage invoices must be issued to the party with ability to move the container. Where we control drayage, invoices should name [Your NVOCC or BCO entity]. Where you control drayage, invoices should name your entity and include your reference IDs.”

Evidence pack language
“In any dispute we attach timestamps of availability posts, appointment attempts, terminal notices, and carrier system status, consistent with FMC incentive principles.”

Minimal SOP For Your Operations Team

Clock: Auto capture ETA, availability, free time type, and last free day. Recalculate on each ETA change.
Appointments: First appointment attempt at least 48 hours before last free day. Escalate after two failed attempts.
Holds: Two hour internal SLA to clear customs, carrier, and terminal holds after status changes.
Disputes: File within the window set by the rule. Include all required invoice fields and your evidence pack.

Turn on last free day and free time alerts in TRADLINX Ocean Visibility. Track berth to availability by terminal, truck turn times where published, and attach your evidence pack to the BL timeline. Use the API to push last free day into your TMS so appointment bots book before the clock runs out.

Assumption Checks

FMC jurisdiction is limited. The billing rule applies to carrier and MTO invoices that fall under the Shipping Act. Foreign port storage outside FMC scope may follow different rules. Call that out in your customer copy.
Evidence beats anecdotes. Only dispute charges you can tie to blocked access with timestamps and notices. Otherwise negotiate commercially.
Quote transparency wins. If you hide variability, you will eat charges. Publish dwell bands and escalation rules up front.