CMA CGM demurrage dispute: what the invoice must show and how to challenge it

What the invoice must show

46 CFR 541.6 says a demurrage or detention invoice must be accurate and, at a minimum, include:

Identifying information: the bill of lading number(s); the container number(s); for imports, the port(s) of discharge; and the basis for why the billed party is the proper party of interest and thus liable for the charge.
Timing information: the invoice date; the invoice due date; the allowed free time in days; the start date and the end date of free time; for imports, the container availability date; for exports, the earliest return date; and the specific date(s) for which demurrage or detention were charged.
Rate information: the total amount due; the applicable rule the daily rate is based on (for example the tariff name and rule number, terminal schedule, or service contract number and section); and the specific rate or rates.
Dispute information: an email, telephone number or other contact for questions or requests for fee mitigation, refund or waiver; a URL, QR code or similar that leads to a public page describing what the billed party must provide; and the timeframes in which the billed party must ask and the billing party will resolve.
Certifications from the billing party that the charges are consistent with the Federal Maritime Commission’s rules on demurrage and detention, and that its own performance did not cause or contribute to the charges.

Source: 46 CFR 541.6 on eCFR , as amended 89 FR 14363 (2024-02-26). The Federal Register notice 90 FR 60579 (document 2025-23920, effective 2025-12-29) says the other provisions of the rule remain in effect.

What a missing item means

Under 46 CFR 541.5 , failure to include any required minimum information eliminates the billed party’s obligation to pay the charge; the FMC’s FAQ adds that the carrier may issue a corrected invoice. So name the missing item in writing, ask for a corrected invoice, and keep the deadline printed on the invoice.

How to dispute with CMA CGM

CMA CGM’s US detention and demurrage dispute guidance says:

A party to the bill of lading or the billed party can dispute, by email to the US disputes address on that page, through the Invoice Dashboard , or through the My Customer Service portal.
Send the completed Dispute Registration Form linked on that page, the bill of lading number, the invoice number, a written description and the resolution you ask for. A waiver request needs credible written evidence, such as appointment-system screenshots. CMA CGM counts a dispute as received only with the form and the documents.
Disputes must be raised within 30 calendar days of the invoice issue date, and CMA CGM aims to resolve them within 30 calendar days.

Write the description with our dispute letter tool .

How Purserhouse checks an invoice

It reads the invoice and lists which of the items above it does not show, only for items it can read from the document.
It compares the free time and the daily rate on the invoice with the carrier’s published US tariff, where we hold it, and flags an invoice only when the amount is above the tariff.
It recomputes the last free day from the discharge or availability date and the free days.
It drafts the dispute letter, a free time extension request or a waiver request, in English, for you to review and send.

It cannot see your contract with the carrier, so a contract may give more than the tariff. Use the last free day calculator for a quick check, and see what we hold of the CMA CGM tariff .

CMA CGM publishes its own US demurrage and detention tariff and its dispute and payment instructions on its site: https://www.cma-cgm.com/. We link to it and do not copy it.

Sources

Updated: 2026-10-21