The FMC needs to pump the brakes and allow the industry to catch up. The Ocean Shipping Reform Act of 2022, passed by Congress without industry input and signed into law on June 16, has left the industry in a difficult position regarding how to comply with the new requirements for invoicing demurrage and detention (D&D) charges. At issue is the Container Availability Date, which must now be included on all invoices as the critical piece of information that determines the fair assessment of D&D charges. However, container availability differs from the date a container is discharged from a vessel,…