Blog
Notes from the D&D desk.
FMC rule analysis, terminal operations and dispute tactics, written by the people who run the audits.
FMC regulation · October 8, 2026
FMC Part 541 explained: the 20 elements every D&D invoice must carry
A field guide to the 20 minimum elements in 46 CFR § 541.6, what § 541.5 does when one is missing, and how to check an invoice line by line.
Arjun Malhotra · 8 min read
Port operations · August 20, 2026 · 7 min
Container availability date disputes: when import free time should start
Why the container availability date on a D&D invoice decides most import demurrage disputes, and how to prove the box could not be picked up.
FMC regulation · June 30, 2026 · 7 min
The 30-day issuance rule: how to spot and dispute late D&D invoices
How 46 CFR § 541.7 sets a 30-day deadline from the date a D&D charge was last incurred, how to count it, and what to do with a late invoice.
Dispute tactics · May 12, 2026 · 8 min
The incentive principle and gate closures: disputing charges you could not avoid
How 46 CFR § 545.5 frames D&D as an incentive, and how to dispute days billed while gates were closed, appointments were full or holds blocked pickup.
FMC regulation · March 17, 2026 · 8 min
Charge complaints under 46 U.S.C. § 41310: when and how to escalate a D&D dispute
What the OSRA 2022 charge complaint process covers, who carries the burden on D&D, what the FMC asks you to submit and when escalation makes sense.
Intermediaries · January 27, 2026 · 7 min
NVOCC pass-through disputes: using the extra 30 days in § 541.7(c)
How NVOCCs caught between carriers and shippers can use § 541.7(b) and (c) to invoice on time, push disputes upstream and avoid absorbing D&D.
Finance & accruals · November 18, 2025 · 7 min
Accruing disputed D&D charges: how finance should treat what is in dispute
A controller's guide to open D&D invoices: sorting Part 541 defects from merits disputes, booking expected credits and forecasting cash.
Port operations · September 30, 2025 · 7 min
Empty return restrictions and per diem: disputing detention when the depot says no
How to dispute detention and per diem billed while empties could not be returned, using § 545.5(c)(2)(ii), terminal notices and trucker records.
Dispute tactics · August 5, 2025 · 7 min
Export earliest return dates and rolled bookings: disputing detention you could not avoid
How exporters can use the ERD element in § 541.6(b)(7) and the incentive principle to dispute detention and demurrage caused by rolls and ERD changes.
Dispute tactics · June 17, 2025 · 7 min
Building a D&D evidence file that gets disputes credited
The documents, event records and captures a detention and demurrage dispute needs, how to organise them, and a worked example of a complete packet.
Don't let your 30-day dispute window expire.
Send your recent D&D invoices for a free audit. We report what is recoverable within 48 hours.