You dispute a demurrage or detention invoice with evidence, inside the window: verify the free time you were actually entitled to, verify when the clock legitimately started, and pull the container’s event history to show whose delay it really was. FMC data makes the case for bothering — roughly 22% of billed D&D was never collected in 2020–22, waived or successfully disputed. These are the most-disputed lines in freight because they are so often wrong, and a documented dispute wins often enough to be a discipline, not a gamble.
How big is the D&D problem, really?
Big enough that the regulator counted. The Federal Maritime Commission reports that nine major carriers collected ~$15.4 billion in D&D charges between April 2020 and March 2025 — a primary-source figure, not a vendor estimate. For a forwarder those charges land as vendor invoice lines: detention on a box, demurrage at a terminal, billed weeks after the event by a carrier whose clock you cannot see.
Does disputing actually work?
The FMC’s own numbers say yes: across 2020–22, carriers billed about $8.9 billion in D&D and collected about $6.9 billion — roughly 22% never collected, waived or disputed away. That fifth of the invoice pool didn’t vanish through charm. It vanished because someone checked the free time, checked the clock, and wrote back with evidence attached.
What evidence wins a D&D dispute?
- Free time: the days your contract or the tariff actually grants — not the carrier system’s default. Wrong free time is the cheapest error to prove.
- Clock start: when the charge legitimately began accruing — discharge, gate-out, availability. A clock that started before the box was available to you is a dispute in one sentence.
- Event history: what the container was actually doing. A customs exam hold, a terminal closure, no available return appointments — delays you didn’t cause and shouldn’t fund.
- The invoice itself: dates, container number, applicable rate, dispute contact. Gaps here weaken the carrier’s position even where they no longer void the bill (see below).
What does the FMC rule require — and what changed in December 2025?
The FMC’s demurrage and detention billing rule choreographs the exchange: carriers must issue D&D invoices within 30 days of when charges stopped accruing, include specified information on the invoice, and resolve disputes within set timelines — a 30-day window is the number to keep on the wall. One caution for anything you read online: the rule’s “properly issued invoices” provision was judicially set aside in December 2025 (Federal Register 2025-23920). An invoice that misses required fields no longer automatically extinguishes your obligation to pay — so a dispute built purely on formality defects stands on struck ground. Build it on evidence instead.
A won dispute without a credit note is just a nice conversation. Track each dispute to the actual credit, and chase until it lands — the desk drafts the dispute with the event history attached, then does exactly that chasing, politely and indefinitely.
The full dispute playbook — free-time verification, clock arithmetic, evidence assembly — is in the complete guide. And if you want to know what your current pile of unchecked D&D lines is plausibly worth, run your volumes through the calculator.
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