DownAnchor checks ocean-carrier D&D invoices against the FMC's billing rule (46 CFR Part 541), flags every disputable charge, and drafts the letter. You review it and send.
HOW IT WORKS
Add your invoice and bill of lading. PDF, scan, or phone photo — messy real-world formats are fine.
DownAnchor checks each invoice against 46 CFR Part 541 and highlights every discrepancy, with the exact regulation cited.
Get a dispute letter citing the specific defect. You review it, decide, and send it to the carrier yourself.
Regulatory radar
The billing rules our audit engine runs on move — court decisions, rule amendments, docket activity. We track the primary sources and surface what changed. Every item below is date-stamped and links to the official record.
In World Shipping Council v. FMC (decided 23 September 2025), the D.C. Circuit set aside 46 CFR §541.4, the provision restricting who a demurrage or detention invoice may be issued to. The Commission has removed §541.4 from the CFR; the rest of Part 541 remains in effect. The FMC may revisit the billing-party question in a future rulemaking.
The FMC's final rule on demurrage and detention billing (89 FR 14330, published 26 February 2024) took effect on 28 May 2024. It sets minimum information requirements for D&D invoices, a 30-calendar-day issuance window after the last charge is incurred, and defined dispute timeframes for billed parties.
General information about regulatory developments, not legal advice and not guidance on any specific invoice or contract. Always refer to the linked primary source.
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