OSRA 2022: your rights on US demurrage & detention invoices
What the US Ocean Shipping Reform Act (OSRA 2022) and the FMC's billing rules require on every D&D invoice — the thirteen required fields, the incentive principle, and how to use non-compliance in a dispute.
What OSRA changed
The Ocean Shipping Reform Act of 2022 rebalanced US demurrage & detention billing. The FMC's rules under it require carriers to issue D&D invoices containing specific minimum information — including the billed party's identity, container and BL numbers, the billing dates and rate basis, the free time start and end, and who to contact to dispute — and set timing rules for issuing invoices and resolving disputes.
Underlying it is the FMC's 'incentive principle' from its 2020 interpretive rule: demurrage and detention are only reasonable when they can actually incentivise cargo movement. Charging for days when the box could not be collected — a government hold the importer didn't cause, a terminal with no appointments — fails that test.
How to use it
On US trades, check every D&D invoice for the required fields before you check the maths. A materially non-compliant invoice is challengeable as issued; cite the FMC billing requirements in the dispute. Then check the days themselves against the incentive principle — document the hold or the appointment shortage and dispute those days specifically.
Outside the US there is no OSRA, but the same logic wins commercially: contracts and reasonableness arguments carry disputes everywhere, and carriers apply their US-grade invoice discipline unevenly across other trades — which is where errors live.
Audit it automatically
Marevo checks invoice compliance, clock starts, contract free time and tariff tiers on every invoice automatically, and drafts the dispute with the right citations for the trade. The first audit is free.
Frequently asked
Does OSRA apply to detention as well as demurrage?
Yes — the FMC's billing requirements cover both demurrage and detention invoices on US trades.
What if the carrier's invoice is missing required information?
Raise it in the dispute: a non-compliant invoice undermines the charge as billed. Carriers frequently reissue or credit rather than defend a defective invoice.
Find out what your last quarter owes you
Marevo reads your invoices against your contracts and the terminal data, drafts the disputes, and is paid mostly from what actually comes back. The audit itself is free.
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