$15.4 billion is a warning signal, not an importer cost benchmark.

Read the $15.4B figure with its denominator attached

The Federal Maritime Commission collects quarterly detention and demurrage data from nine named ocean carriers. It reports roughly $15.4 billion collected between April 1, 2020 and March 31, 2025. The FMC chart indexes billed, collected, and waived amounts to Q2 2020: billed amounts rose roughly ninefold and collected amounts roughly tenfold by Q1 2022.

The series is not a total for every carrier, terminal, shipper, or logistics charge. It does not report the number of containers behind the dollars, a per-container average, the share caused by importer action, or savings attributable to software.

The invoice clock is separate from the free-time clock

The FMC's 2024 billing rule established invoice-content, timing, and dispute-process requirements. Its announcement states that invoices generally must be issued within 30 calendar days and billed parties receive at least 30 calendar days to request mitigation, refund, or waiver. In September 2025, a court set aside the rule's section 541.4 on who may be invoiced; the FMC says the other provisions remained in effect.

Operational teams should therefore retain current legal guidance rather than relying on an old checklist. They also need two timelines: the physical timeline that explains terminal time or equipment use, and the billing timeline that explains invoice receipt, review, evidence request, dispute, response, waiver, and payment.

Dispute data reinforces the evidence gap

An FMC report published in its reading room says few responding vessel-operating common carriers and marine terminal operators supplied meaningful statistics on the number or resolution of disputes; many said they did not track complaints or disputed charges. The report describes refunds as rare among respondents and practices as varied, with many informal.

That finding should not be converted into a refund probability. It supports a narrower operating lesson: keep your own invoice and dispute record complete enough to measure outcomes rather than assuming an industry average exists.

• Tie the charge to container, MBL, shipment, terminal, carrier, and invoice identity.
• Preserve free-time terms and the source and time at which they were observed.
• Keep availability, pickup, gate-out, empty-return, closure, and appointment evidence distinct.
• Record billed, disputed, waived, refunded, and paid amounts separately by currency.
• Measure resolution time and outcome without treating every waiver as proof of an invalid charge.

How Tyllus supports container-cost evidence

Tyllus can keep container and ETA context, shipment documents, partner follow-up, cost lines, invoices, and owner-visible exceptions connected to the same shipment record. That supports earlier review and a more traceable handoff between operations and finance.

Tyllus does not determine free-time terms, validate an invoice under current law, submit an FMC complaint, control cargo availability or empty return, or guarantee avoidance, waiver, refund, or savings. Teams must confirm terms and remedies with carriers, terminals, counsel, and the FMC as appropriate.