NVOCC · About 4,200 TEU / year for roughly 70 shipper clients, mostly through Port Houston's Barbours Cut and Bayport terminals
A Houston NVOCC cut D&D write-offs from $118,000 a year to $21,000 by disputing upstream before billing clients
Caught between carriers billing it and clients refusing to pay, the NVOCC was absorbing D&D it could not pass through. ATAHSKIA audited every carrier and terminal invoice before re-billing, issued compliant pass-through invoices inside the § 541.7(b) window, and used § 541.7(c) notices when clients disputed.
- 50%
- Upstream D&D recovered or invalidated
- $118K to $21K
- Annual D&D write-offs
- 100%
- Client invoices issued with all 20 elements
The challenge
The NVOCC moves about 4,200 TEU a year for some 70 importers and exporters, from resin and chemicals exporters to consumer goods importers, most of it through Barbours Cut and Bayport. As a billing party it re-invoices its clients for carrier and terminal D&D; as a billed party it receives those charges from ocean carriers and terminals first.
Its finance team paid upstream invoices to keep bookings flowing and then re-billed clients, often weeks later. When Part 541 took effect, clients began rejecting pass-through invoices that lacked the required elements or arrived after the NVOCC's 30-day deadline under § 541.7(b). The NVOCC had already paid the carrier, so it wrote off $118,000 of D&D in the year before it adopted ATAHSKIA.
Fog closures on the Houston Ship Channel and congestion days at the terminals also produced charges that clients argued, correctly, they could not have avoided. Nobody had time to build the evidence.
The approach
Audit upstream before paying
Carrier and terminal invoices are now routed to the OSRA Audit Engine first. Invoices that fail a § 541.6 or § 541.7 check are disputed before payment, so the NVOCC is not funding charges its clients would later reject.
Client workspaces and compliant re-billing
Each shipper client has its own workspace and ledger. Pass-through invoices are generated with all 20 elements, the NVOCC's own certifications and a dated link to its relief request instructions, and issued well inside the 30 days that § 541.7(b) allows from the date of the upstream invoice.
§ 541.7(c) notices when clients dispute
When a client disputes a pass-through charge, the platform sends the upstream carrier or terminal a § 541.7(c) notice, which entitles the NVOCC to an additional 30 days to dispute the original charge, and builds that dispute from the client's evidence.
Closure and congestion evidence
Milestone & Gate Tracking matched billed days against terminal advisories, appointment availability and gate records for Barbours Cut and Bayport, so days lost to channel closures or full appointment calendars carried documentation into the dispute.
The results
- Over 12 months, ocean carriers and terminals billed the NVOCC $684,000 in D&D. It recovered or had invalidated $342,000, 50% of the billed total, before or after payment.
- D&D write-offs fell from $118,000 the prior year to $21,000, almost all of it on charges where the client caused the delay and paid late.
- Every pass-through invoice in the period carried all 20 § 541.6 elements and issued inside the § 541.7(b) window. Client disputes of pass-through invoices dropped by more than half.
- The NVOCC sent 46 § 541.7(c) notices; in 31 of those cases the upstream charge was reduced or withdrawn.
- Per-client recovery statements are now part of the NVOCC's quarterly business reviews with its largest shippers.
“We were the ones holding the bag. The carrier had our money and the client had a perfectly good reason not to pay us. Now we check the carrier's invoice before we pay it, and our own invoices to clients hold up.”
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