OCEAN D&D DEADLINE TRIAGE

Demurrage & detention invoice deadline checklist.

Use this checklist to preserve the dates and documents that determine whether a D&D invoice deserves urgent review. Do not rely on memory or a portal view that may change later.

1. Capture the invoice dates

Invoice issue date

Save the original invoice showing when it was issued.

Date received

Preserve evidence of when your company actually received it.

Last charge date

Identify the last date the D&D charge was incurred when supported by records.

2. Identify who billed you

Record whether the billing party is a vessel-operating common carrier, marine terminal operator, NVOCC, or uncertain. The applicable issuance calculation can depend on the billing-party type and the available upstream invoice evidence.

3. Preserve the operational timeline

Cargo availability

Availability notice/date and relevant terminal evidence.

Pickup / out-gate

Document when the container was picked up.

Empty return

Preserve return date, appointments and inability-to-return evidence if applicable.

4. Check the 30-day windows

The FMC states that the D&D rule still includes a 30-day invoice-issuance deadline. The final rule also provides billed parties at least 30 calendar days to request fee mitigation, refund, or waiver, and requires the billing party to attempt resolution within 30 days after a timely request unless the parties agree to a longer timeframe.

Primary sources: FMC 2025 court-decision advisory · FMC final-rule summary.

5. Escalate evidence, not assumptions

Recovery OS treats missing anchor dates as missing evidence rather than an automatic violation. Cases with seven days or less remaining in an evidenced applicable window are designed to enter a P0 deadline-risk queue for human review.

Educational workflow, not legal advice. Rules, contracts and facts must be checked for each invoice. Recovery OS does not automatically send a carrier dispute or FMC complaint.

Request an evidence-backed screen