In related news, the FMC is also seeking comment on a proposed rule that would require common carriers and marine terminal operators to include minimum and specific information on future demurrage and detention invoices.  IAM was among the earlier commenting industries on D&D billing practices, when the Commission issued its Advanced Notice of Proposed Rulemaking, earlier this year. In our comments, the Association focused on billing clarity, consideration of intervening events and other factors out of control of the shipping entity.

The proposed rule includes party billing requirements, invoice issuance timeframes, and which party may be billed, among other considerations. While the proposed requirements are overall positive, the proposed rule also requests feedback on who may be billed, including whether or not it would be appropriate to bill the consignee, for D&D expenses. IAM will clarify in comments that this would not be appropriate in the case of HHG shipments.

IAM intends to submit comments to the proposed rule next week. If your company would like to submit comments the deadline is Tuesday, December 13th.