BCO importer · About 18,000 TEU / year of furniture, decor and housewares through San Pedro Bay (Los Angeles and Long Beach)
A home goods retailer recovered or invalidated $1.08M of D&D in its first year, 55% of what carriers and terminals billed
With 18,000 TEU a year landing in San Pedro Bay and a three-person import team, the retailer was paying most D&D invoices without checking them. ATAHSKIA audited every invoice against the 20 elements of 46 CFR § 541.6, matched billed days to terminal availability and empty-return records, and moved dispute submission from 34 days after receipt to 3.
- $1.08M
- Recovered or invalidated, first 12 months
- 55%
- Share of billed D&D recovered
- 34 days to 3
- Invoice receipt to dispute
The challenge
The retailer imports roughly 18,000 TEU a year, almost all of it in 40-foot high cube containers discharged at Los Angeles and Long Beach and drayed to two distribution centers in the Inland Empire. D&D came from six ocean carriers and several marine terminals, as PDF invoices emailed to a shared mailbox, as portal statements and as line items on freight bills.
Three import coordinators handled D&D alongside booking, customs and DC scheduling. They disputed about one invoice in nine, usually only the largest, and the average dispute went out 34 days after the invoice arrived. That is past the 30-day minimum relief window Part 541 guarantees, which meant many disputes reached billing desks after the carrier considered the matter closed.
Finance had no way to accrue disputed charges with confidence, so D&D was booked as paid and reported as a single annual number of about $1.96M that nobody could break down by cause.
The approach
Retrospective audit first
The team exported 12 months of D&D invoices and remittances. ATAHSKIA checked 4,120 invoices in 48 hours: 2,790 (67.7%) failed at least one Part 541 check. The most common gaps were a missing container availability date, no cited tariff rule or contract section, and invoices issued more than 30 days after the charge was last incurred. Paid charges on those invoices totaled $612,000.
Every new invoice audited on arrival
The shared D&D mailbox and carrier portal exports were routed into the OSRA Audit Engine. Each invoice was checked against all 20 elements and the § 541.7 issuance deadline the day it arrived, and the dispute clock for each one appeared in the coordinators' queue.
Billed days matched to terminal reality
Milestone & Gate Tracking pulled carrier status events and terminal records for every billed container and compared them with the free time start date, availability date and empty return on the invoice. Days with no open pickup or empty-return appointments, terminal holds or refused empties were flagged for incentive-principle disputes under 46 CFR § 545.5.
Cited disputes sent inside the window
Automated Disputes built a packet per invoice citing the exact § 541.6 subsection or the § 545.5 ground, with appointment screenshots, gate records and hold timestamps attached. Coordinators reviewed and approved packets in batches; the platform dispatched them to each billing desk and tracked the billing party's 30-day resolution deadline.
The results
- In the first 12 months live, carriers and terminals billed $1.96M in D&D. The retailer recovered or had invalidated $1,078,000 of it, 55% of the billed total. On the High-Volume Fleet plan ($5,900 a month, no success fee) that is about 15 times the annual platform cost of $70,800.
- $340,000 of that came in the first 90 days, most of it from invoices that omitted the container availability date or the applicable rule and were withdrawn or credited on first request.
- Refund requests on the retrospective findings have returned $186,000 of the $612,000 in paid charges sitting on deficient invoices so far.
- Of 14 disputes the billing party denied, 11 were reversed after a second relief request with additional gate evidence. ATAHSKIA compiled charge complaint dossiers under 46 U.S.C. § 41310 for the remaining three, which the retailer's trade counsel is reviewing.
- Finance now accrues disputed D&D by invoice and status, and Carrier Scorecards feed the retailer's annual carrier allocation review.
“We used to pick the five biggest invoices each month and hope. Now every invoice gets checked the day it lands, and the disputes go out with the gate records already attached. Billing desks credit most of them without a phone call.”
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