What exactly changed at the FMC regarding charge complaints?

The FMC confirmed that there is no three-year statute of limitations on charge complaints for fees assessed on or after June 16, 2022. Previously, carriers could argue that complaints were time-barred after three years; that protection no longer applies to post-June 2022 charges, leaving them exposed to indefinite claims.

How does this affect ocean carriers' financial risk?

Carriers now face open-ended liability for charge disputes, meaning a shipper or cargo interest holder can challenge fees years after they were assessed. This eliminates the legal finality that a three-year window once provided, forcing carriers to maintain records and prepare for potential retrospective claims indefinitely.

Why does this matter for shippers and supply chain managers?

Shippers gain extended leverage to contest historical fees, but they also face uncertainty about carrier billing practices going forward. Carriers may respond by raising rates to offset risk, implementing stricter billing documentation, or becoming more cautious with fee assessments—all of which could increase supply chain costs and complexity.

Does this rule apply to all maritime charges?

The article specifically addresses charge complaints—a formal mechanism for challenging carrier fees. This applies to fees assessed on or after June 16, 2022. The scope of which specific fee types are covered under this unlimited complaint window requires further regulatory clarification.

What should companies do in response to this ruling?

Supply chain teams should audit historical charge assessments from mid-2022 onward, request detailed justifications from carriers for all fees assessed, ensure internal billing records are complete and defensible, and monitor for rate increases as carriers adjust pricing to account for increased liability exposure.

Trade Policy & Tariffs

High Impact

FMC Removes Statute Limits on Carrier Charge Complaints

Sep 22, 2026

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The signal

The US Federal Maritime Commission has eliminated the three-year statute of limitations on charge complaints for fees assessed on or after June 16, 2022—a regulatory shift that significantly expands carrier exposure to retrospective fee challenges. This change removes a critical legal protection that previously allowed carriers to treat complaints as time-barred after three years, fundamentally altering the risk calculus for ocean freight businesses. For supply chain professionals and shippers, this development creates both operational uncertainty and potential leverage in fee disputes.

The open-ended nature of complaint windows means that charges assessed years ago could still be challenged, forcing carriers to maintain indefinite documentation and audit trails while potentially incentivizing shippers to revisit historical billing arrangements. This regulatory move effectively transfers more risk onto carrier shoulders, which may eventually manifest in higher freight rates or stricter billing practices. The implications ripple across global trade networks: carriers operating on US trade lanes face unprecedented compliance and financial exposure, while shippers gain extended opportunities to contest fees.

Supply chain teams should immediately audit historical charge assessments, clarify fee justifications with carriers, and anticipate potential rate adjustments as carriers build in risk premiums to offset unlimited liability windows.

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Frequently Asked Questions

What This Means for Your Supply Chain

Simulation Suggestion

this month

What if carriers implement 3-5% rate increases to offset unlimited charge complaint liability?

Model the impact of ocean carriers raising freight rates by 3-5% across all US-bound shipments to build in risk premiums associated with unlimited charge complaint exposure. Simulate effects on total supply chain costs, margin compression, and potential sourcing route alternatives.

Run this scenario

Simulation Suggestion

this week

What if shippers launch retrospective charge audits on 2022-2024 shipments?

Model the internal compliance and operational burden if shippers systematically audit and challenge historical carrier charges from June 2022 onward. Simulate effects on dispute management team capacity, legal resource allocation, and potential cost recoveries versus administrative friction.

Run this scenario

Simulation Suggestion

strategic

What if carriers tighten billing documentation and dispute resolution timelines?

Simulate the operational impact of carriers requiring stricter shipment documentation, faster payment windows, and more detailed charge justifications to mitigate unlimited complaint exposure. Model effects on invoice processing cycles, payment terms, and dispute resolution workload.

Run this scenario

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