46 CFR Part 541 · effective May 28, 2024
Twenty elements. Thirty days. Checked on every invoice.
The audit engine reads each carrier and terminal invoice the way the FMC billing rule does, and tells you which ones carry no obligation to pay.
Interactive
Toggle what the carrier printed.
Remove an element or push the issuance date past 30 days and watch the verdict change, citation by citation.
12 days · inside 30 days
No obligation to pay as issued
2 of 19 applicable elements missing (§ 541.5).
46 CFR § 541.6
The minimum information every invoice must carry.
Omitting any of it eliminates any obligation of the billed party to pay the charge (§ 541.5).
Identifying
Bill of lading number(s) § 541.6(a)(1)
Every B/L the charge relates to, so the billed party can tie the invoice to a shipment.
Container number(s) § 541.6(a)(2)
The specific equipment billed. Charges cannot be pooled across unnamed containers.
Port(s) of discharge (imports) § 541.6(a)(3)
Where the container was discharged, which sets the terminal and free-time context.
Basis for billed-party liability § 541.6(a)(4)
Why the recipient is the proper party: the contracting party for carriage or storage, or the consignee.
Timing
Invoice date § 541.6(b)(1)
Starts the billed party's dispute window and proves the 30-day issuance deadline was met.
Invoice due date § 541.6(b)(2)
When payment is due. Must leave room for the 30-day relief request window.
Allowed free time in days § 541.6(b)(3)
The free time granted under the tariff, contract or terminal schedule.
Start date of free time § 541.6(b)(4)
The day free time began. Often wrong when availability lagged discharge.
End date of free time § 541.6(b)(5)
The last free day. Billing must begin after it, not on it.
Container availability date (imports) § 541.6(b)(6)
When the box was actually available for pickup. The most frequently omitted element.
Earliest return date (exports) § 541.6(b)(7)
The first day the terminal would accept the export load.
Specific dates charged § 541.6(b)(8)
Each calendar day for which demurrage or detention accrued.
Rate
Total amount due § 541.6(c)(1)
The full amount billed.
Applicable rule or contract § 541.6(c)(2)
Tariff name and rule number, terminal schedule, or service contract number and section.
Specific rate(s) § 541.6(c)(3)
The per-day rate or tiered rates applied under that rule.
Dispute
Contact for questions and relief requests § 541.6(d)(1)
A named route (email, phone or portal) for mitigation, refund or waiver requests.
URL, QR code or digital watermark § 541.6(d)(2)
A digital pointer to a public page describing what a relief request must include.
Dispute and resolution timeframes § 541.6(d)(3)
The window to request relief and the billing party's own resolution deadline.
Certification
Certification of FMC rule consistency § 541.6(e)(1)
A statement that the charges are consistent with the Commission's D&D rules.
Certification of no contributing performance § 541.6(e)(2)
A statement that the billing party's own performance did not cause or contribute to the charges.
46 CFR § 541.7
The issuance clock runs against the billing party.
Timing defects void an invoice even when every element is printed.
§ 541.7(a)
30 days from the last charge
A billing party must issue the invoice within 30 calendar days of the date the charge was last incurred. The engine computes the lag from out-gate or empty in-gate events, not from the invoice's own claims.
§ 541.7(b)
NVOCC invoices
An NVOCC passing a charge through must issue its invoice within 30 days of the issuance date of the invoice it received. Forwarder workspaces check both legs.
§ 541.7(c)
Pass-through disputes
When the NVOCC's customer disputes, the NVOCC can notify its own billing party, which then must allow an additional 30 days for the NVOCC to dispute. The engine opens that window automatically.
§ 541.7(d)
Wrong-party invoices
A billing party that invoiced the wrong person may reissue to the correct party, but only within 30 days of the date the charge was last incurred. Late reissues are flagged.
What the engine sees
Built for the way invoices actually arrive.
68.4%
of invoices audited on ATAHSKIA failed at least one Part 541 check
Most invoices fail on something.
The most common gaps are the container availability date, the certification that the billing party did not contribute to the charge, and the public dispute URL or QR code.
PDF, EDI 310, CSV
Carrier PDFs are parsed field by field; EDI and CSV invoices map directly. Multi-container invoices are split per box.
Free time, recomputed
Free time is recounted from availability and checked against the tariff or service contract rule printed on the invoice.
Cited findings
Every flag carries its CFR paragraph so the dispute packet can quote the rule exactly.
AP holds
Non-payable invoices are held in your AP system with the reason code until the billing party responds.
“The audit catches missing certifications and late invoices automatically. We stopped arguing about whether the rule applied and started quoting it.”
Scope
What the engine does not decide.
A complete, timely invoice is properly issued, which is not the same as reasonable. Whether a charge served its purpose of moving cargo and equipment is a separate question under 46 U.S.C. § 41102(c) and the Commission's interpretive rule at 46 CFR § 545.5. That analysis runs in Milestone & Gate Tracking.
ATAHSKIA is audit software. It identifies defects and prepares the record. Your team approves every dispute, and legal judgments stay with you and your counsel.
Audit engine FAQ
Why 20 elements and not 13?
Industry summaries of the rule often group elements differently, and some counted earlier drafts. The rule as published in 46 CFR § 541.6 lists twenty minimum items across identifying, timing, rate, dispute and certification information. The engine checks each one against its paragraph citation.
What happens when an element applies only to imports or exports?
Container availability date and port of discharge apply to imports; earliest return date applies to exports. The engine reads the direction from the B/L and milestone data and only tests the elements that apply.
Does a complete invoice mean the charge is fair?
No. A properly issued invoice can still bill days when the terminal was closed or no appointments existed. Complete invoices move on to free-time and blocked-day checks in Milestone & Gate Tracking.
How fast is an audit?
Invoices are parsed and checked as they land in the connected inbox or TMS, usually within a minute of receipt. Results post to the invoice record and to your AP exception queue.
More of the platform
- Learn more
Milestone & Gate Tracking
Reconciles availability, gate, appointment and empty-return events against what was billed.
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Automated Disputes
Builds cited, evidence-backed dispute packets and tracks the carrier's 30-day reply.
- Learn more
FMC Charge Complaints
Compiles complaint dossiers under 46 U.S.C. § 41310 when a dispute is wrongly denied.
- Learn more
Carrier Scorecards
Ranks every carrier and terminal in your book by billing accuracy and credit behaviour.
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