2026-17876RuleWallet

Sue Your Shipper Faster: FMC's New Fee Fight Rules Kick In

Published Date: 9/1/2026

Rule

Summary

Starting September 1, 2026, people can file complaints about shipping charges either through a quick interim process or a traditional legal route with a judge or small claims officer. Shipping companies must prove their fees, like demurrage or detention charges, are fair. This change helps anyone dealing with unfair shipping fees get their issues sorted faster and clearer, with no extra cost signals mentioned.

Analyzed Economic Effects

5 provisions identified: 4 benefits, 0 costs, 1 mixed.

Choice: Fast Interim or Formal Route

Starting September 1, 2026, you may file a Charge Complaint either through the Commission's streamlined Interim Procedure or by filing a traditional private party formal complaint (Sec. 502.62) or a small claims complaint (Sec. 502.304). The Interim Procedure and traditional processes may not run at the same time, and you may not file a duplicate claim that has been decided on the merits.

Carrier Must Prove Demurrage/Detention Charges

If you file a Charge Complaint as a traditional complaint (with an Administrative Law Judge or Small Claims Officer), the common carrier must bear the burden of establishing the reasonableness of any demurrage or detention charges pursuant to 46 U.S.C. 41310(b)(2) and 46 CFR 545.5.

No Time Limit For Charge Complaints

There is no statute of limitations for Charge Complaints under 46 U.S.C. 41310; you may file a Charge Complaint for charges or fees assessed on or after June 16, 2022 (the date OSRA 2022 became effective). OSRA 2022 does not apply retroactively to charges before that date.

Interim Route Currently No Fee; Formal Filing Fees Apply

Under the Interim Procedure you currently do not pay a fee, while filing a private party formal complaint requires a filing fee (currently $387 for Subpart E) and filing a small claims complaint requires a filing fee (currently $176 for Subpart S). The Commission may consider fees for the Interim Procedure later through rulemaking.

Small Claims Cap and Civil Penalty Treatment

Small claims under subpart S are capped at $50,000 and require both parties' consent to proceed under informal adjudication; civil penalties are not part of the $50,000 claim limit, cannot be requested by claimants in private party complaints, and, if assessed, are payable to the U.S. Treasury General Fund (separate from reparations).

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Key Dates

Published Date
Rule Effective
9/1/2026
9/1/2026

Department and Agencies

Department
Independent Agency
Agency
Federal Maritime Commission
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