Most demurrage advice starts one step too late. It teaches you to read the invoice, check the last free day and dispute the errors, all of which assumes the charge was yours to owe. On a shipment you booked door delivery for, moving under a through B/L, that assumption may be wrong.

Your exposure on a store-door booking depends partly on who was responsible for the inland move when the charge accrued. If that responsibility changes mid-transit and the change is not recorded anywhere your team looks, the first sign can be a rail storage line item on an invoice for a move you thought the carrier had undertaken to complete. That is one of the allegations at the centre of the Federal Maritime Commission complaint Samsung Electronics America served on CMA CGM on 1 September 2026.

Who pays demurrage on a store-door shipment?

On a store-door shipment under a through B/L, the carrier is responsible for arranging transportation to the contracted inland destination. That does not automatically make the carrier responsible for every demurrage, detention or storage charge incurred along the way. Liability still depends on the applicable service contract or tariff and on what caused the delay.

Store door is carrier haulage. The carrier arranges the inland movement, including the relevant rail or drayage providers, as part of the contracted transportation. CY is different: the carrier’s delivery obligation ends at the named container yard or other CY point, and the cargo interest or its forwarder takes responsibility for transportation beyond that point.

That distinction matters in a dispute because a charge caused by the carrier’s failure to perform an inland obligation is different from one caused by the consignee’s own inability to receive or move the container. The service mode tells you who was supposed to perform the leg. It does not, by itself, settle every charge.

What a store-door to CY conversion actually changes

A conversion is more than a rate change. It can change who is responsible for arranging the final transportation leg and therefore which operational actions your team must take.

What changes	Store door (carrier haulage)	CY / merchant-arranged onward movement
Who arranges the inland move covered by the booking	Carrier	You or your forwarder beyond the named CY point
Where the carrier’s delivery obligation ends	The contracted inland destination	The named CY, terminal or rail-ramp delivery point
Who must arrange onward pickup	Carrier for the contracted inland leg	You or your forwarder
What the carrier transportation covers	Transportation through the contracted door destination	Transportation through the named CY/place of delivery
Which party’s actions matter in a delay dispute	Carrier performance and consignee availability both matter	Your ability to retrieve and move the container becomes central
What you must establish in a dispute	Who controlled the relevant leg and what caused the charged delay	Whether the container was available and whether you could retrieve or return it

The clock also needs to be identified rather than assumed. Store-door versus CY does not by itself establish a universal free-time start date. The relevant window depends on the particular charge, location and governing tariff or service contract. Terminal demurrage, carrier detention and rail storage can each run under different rules. Which deadline actually governs is a question carrier LFD versus terminal LFD works through in detail.

What Samsung alleges in FMC Docket 26-12

The Federal Register noticed the complaint on 4 September 2026. Samsung alleges CMA CGM violated 46 U.S.C. 41102(c) along with 46 CFR 545.4 and 545.5, arising from demurrage and detention charges tied to delays outside Samsung’s control, failure to perform inland transportation obligations, and improper cargo holds, billing and dispute practices. An answer is due within 25 days of service, which falls in late September. Nothing has been decided.

The alleged facts, per the complaint and reporting by Container News:

• CMA CGM began carrying Samsung containers on store-door bills of lading in January 2020, and from around mid-2020 allegedly failed to remove containers from marine and intermodal terminals in time.
• Samsung says it paid more than 121,000 charges in total, comprising over 26,000 demurrage charges and over 94,000 detention-type charges.
• CMA CGM allegedly converted some store-door shipments into CY movements without Samsung’s approval, leaving Samsung to arrange inland transport the carrier had undertaken to provide.
• One 2021 container moving Busan to Long Beach to The Colony, Texas allegedly accumulated roughly US$162,800 in rail storage after being converted from store door to CY.
• Samsung alleges CMA CGM applied finance holds that withheld release of containers unrelated to the disputed invoices.
• Reparations sought total at least US$186 million: US$148m in charges, US$8.1m in mitigation costs including extra staff and off-dock yard space, and US$30m in prejudgment interest.

Every figure above is Samsung’s own accounting of what it says it was billed. None is a published tariff rate, and none has been tested. This is the seventh complaint Samsung has brought against an ocean carrier since 2022 and one of its largest claims by dollar value. The two that have reached an initial decision produced awards well below the amounts claimed, for reasons covered in the documentation standard that cost Samsung $23M across two FMC rulings.

How to tell whether your move was converted

A store-door to CY change may not arrive as a prominent standalone notice. Operational records can reveal that responsibility for the inland move has shifted. Six signals worth checking on any door booking into the US:

1. Rail or ramp storage line items appear on a shipment you booked door to door.
2. The delivery order comes to you rather than to the carrier’s appointed drayage vendor.
3. The gate-out event carries your trucker’s SCAC, not the carrier’s.
4. Availability and appointment notifications arrive at your address instead of at the carrier’s inland vendor.
5. The free-time basis on the invoice does not match the service scope you understood the booking to have.
6. The tariff rule or service-contract provision cited on a covered demurrage or detention invoice points to different delivery terms. Under Part 541, a covered invoice must identify the tariff rule or service-contract section on which the daily rate is based.

No single signal proves that a conversion occurred. Establishing whether responsibility changed, and when, requires matching the booking terms against container-level operational records and the days for which charges accrued. Reconstructing that after the fact from mailbox threads and portal screenshots makes the dispute substantially harder. The event set you need is the same one mapped in container tracking milestones, read for liability rather than for ETA.

If your team is reconstructing which party controlled the inland leg only after an invoice arrives, walk through how ops teams keep container-level event records lined up against each charged day.

Which FMC rules give you leverage today

One point of sequencing first. Part 541, the FMC’s demurrage and detention billing requirements rule, took effect on 28 May 2024. Samsung’s charges run from mid-2020, so its complaint proceeds under 46 U.S.C. 41102(c) as interpreted by 46 CFR 545.4 and 545.5. Part 541 is not Samsung’s route for those earlier charges. It applies to covered demurrage and detention invoices issued on or after 28 May 2024.

46 CFR 541.4 is now reserved. The D.C. Circuit set it aside on 23 September 2025, and the Commission removed it from the CFR in a final rule published 29 December 2025. That was the provision restricting which parties a carrier could bill. Worth noting why it fell: the court found the Commission had not adequately explained the treatment of motor carriers that hold contracts with ocean carriers under carrier-haulage arrangements. The provision that spoke most directly to which party could be billed is therefore no longer in force. What changed after the court decision covers the fallout.

The remaining invoice requirements still matter. Under 46 CFR 541.6(a)(4), the invoice must state the basis for why you are the proper party of interest and therefore liable for the charge. Under 541.6(c)(2), it must name the tariff rule or service-contract section on which the daily rate is based. Under 541.6(e)(2), the billing party must certify that its own performance did not cause or contribute to the charge. Under 541.5, failure to include required information eliminates the billed party’s obligation to pay that invoice.

On a disputed carrier-haulage move, those fields give you concrete points to test. If the billing party’s own failure to perform the inland leg caused or contributed to the delay, the certification required by 541.6(e)(2) becomes difficult to reconcile with the underlying events. The invoice audit checklist walks the full field set.

The windows. Under 541.7, a billing party generally has 30 calendar days from the date the covered demurrage or detention charge was last incurred to issue the invoice, and a late invoice is unenforceable under Part 541. Under 541.8, you get at least 30 calendar days from invoice issuance to request mitigation, refund or waiver, and the billing party must attempt to resolve the request within 30 days after receiving it.

Why the reparations route is a last resort. For a §41102(c) claim under §545.4, the claimant must establish five elements, including that the challenged practice occurred on a normal, customary and continuous basis. An isolated bad invoice therefore generally will not satisfy that particular standard. A repeated pattern can, which is why Samsung’s filings are built around charge counts in the tens of thousands. The fifth element requires the practice to be the proximate cause of the loss. Section 545.5 then evaluates demurrage and detention practices against the incentive principle, including whether a charge could actually have encouraged cargo movement. Docket 26-12 has an initial decision due 1 September 2027 and a final Commission decision due 15 March 2028. The paperwork discipline matters long before the remedy.

What to check on your next store-door invoice

• Does any line item name rail storage, ramp storage or terminal storage on a booking sold as door delivery?
• Does the tariff rule or service-contract provision named on a covered D&D invoice match the transportation scope you booked?
• What event started the free-time clock, and does that match the applicable tariff or contract?
• Is the carrier’s 541.6(e)(2) certification present on a covered D&D invoice, and do the operational records support it?
• Was the covered demurrage or detention invoice issued within the applicable Part 541 billing period?
• Do your own event records show the carrier’s drayage vendor or yours on the gate-out?
• If responsibility for the inland move changed part way through the shipment, on what date did it change and what document or operational event shows that?

Once liability is established, the dispute mechanics take over. Before that, the more important question is who was responsible for the relevant transportation leg, what caused the delay, and which terms governed the charge.

Frequently asked questions

Can a carrier convert a store-door booking to CY without my agreement?

Whether it can depends on your service contract and the carrier’s B/L terms. Samsung alleges CMA CGM converted shipments without approval, and the FMC has not ruled on that allegation. What matters operationally is that a conversion can change who is responsible for arranging the remaining inland transportation, making the effective date and governing terms central to any later dispute.

Is rail storage the same as demurrage?

No. Demurrage generally concerns container time at a marine terminal or other facility before removal under the applicable tariff or contract. Detention concerns equipment use after pickup. Rail storage is assessed under the railroad’s own rules and can accrue while a container is moving through an intermodal network. Part 541’s demurrage and detention invoice requirements do not automatically apply to every railroad storage charge.

Does 46 CFR 541.4 still restrict who a carrier can bill?

No. It was set aside by the D.C. Circuit on 23 September 2025 and removed from the CFR by a final rule published 29 December 2025. The section is reserved. The rest of Part 541 remains in force, including invoice-content requirements and billing and dispute windows for covered demurrage and detention invoices.

Need help interpreting this disruption or your shipment?
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Further Reading

• Federal Register: Notice of Filing of Complaint and Assignment, Docket No. 26-12
• Container News: Samsung files US$186 million FMC claim against CMA CGM
• eCFR: 46 CFR Part 541, Demurrage and Detention
• eCFR: 46 CFR 545.5, unjust and unreasonable practices with respect to demurrage and detention
• FMC: U.S. Court of Appeals issues decision on demurrage and detention billing practices

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Sourcing: Docket number, alleged statutory and regulatory violations, service date of 1 September 2026, and the 1 September 2027 and 15 March 2028 decision deadlines are from the Federal Register notice published 4 September 2026 (91 FR 56886). Charge counts, damages breakdown, the January 2020 store-door start date, the alleged store-door to CY conversions, the Busan to The Colony rail storage figure and the finance-hold allegation are from the Samsung complaint and Container News reporting published 7 September 2026. All Samsung figures are allegations that have not been adjudicated and are not carrier tariff rates. Regulation text and the reserved status of 46 CFR 541.4 are from the eCFR; the set-aside date and removal rule are from the FMC and Federal Register. The allocation of liability for any individual charge depends on the applicable tariff, service contract, bill of lading terms and the events that caused the delay. Confirm any charge against your own governing terms.