
The Ocean Shipping Reform Act of 2022 (OSRA), which came into effect in June 2022, represents the most significant overhaul of US maritime regulations in decades. Passed in response to mounting concerns over excessive freight charges, unpredictable demurrage and detention fees, and opaque shipping practices, OSRA aims to create a more transparent, fair, and competitive ocean freight market. The Act strengthens the authority of the Federal Maritime Commission (FMC) to oversee carrier practices, mandates clearer billing for demurrage and detention, and improves public access to freight rate information. For US importers, OSRA provides a framework to enhance supply chain visibility and ensure shipping charges align with actual service performance.
One of OSRA’s key provisions requires ocean carriers and terminal operators to issue demurrage and detention invoices that are accurate, detailed, and compliant with FMC standards. The FMC is empowered to investigate complaints regarding excessive charges and to enforce penalties against carriers and terminals that engage in unfair practices. This regulatory shift places new responsibilities on importers to monitor and verify freight charges effectively. Leveraging the FMC’s open-data freight rate index is a critical first step in this process. The freight rate index, maintained by the FMC and accessible through its public data portal, provides detailed benchmarks of average shipping costs by route, carrier, and container type. Importers can integrate this index into their freight procurement and invoice validation processes to assess whether rates charged by carriers are reasonable and consistent with market norms.
To integrate the FMC freight rate index effectively, importers should begin by establishing data pipelines that feed the index’s published rates directly into internal freight management systems or procurement platforms. Modern enterprise resource planning (ERP) or transport management systems (TMS) often include application programming interface (API) functionality that allows for automated data ingestion from external sources. Importers should configure these systems to match inbound freight invoices against the benchmark rates for the relevant shipping lane, carrier, and time period. Significant deviations between invoiced rates and the benchmark should trigger internal review or escalation processes, ensuring that importers have a defensible basis for questioning charges that appear excessive under OSRA’s transparency requirements.
Beyond rate benchmarking, OSRA has prompted leading importers to take a more proactive approach to freight spend reporting. Companies are increasingly expected to document and disclose their ocean freight expenditures as part of their broader sustainability, cost-control, or compliance reporting obligations. Developing an annual freight spend report that aligns with OSRA’s transparency goals can strengthen supplier governance and enhance relationships with regulators and customers. Such reports should present freight costs broken down by Standard Carrier Alpha Code (SCAC), vessel, route, and shipping partner. Importers can enrich these reports by incorporating vessel tracking data obtained via ADS-B (Automatic Dependent Surveillance–Broadcast) or AIS (Automatic Identification System) signals, linking freight spend directly to vessel movements and service performance.
Creating a robust annual freight spend report starts with accurate data capture at the shipment level. Importers should record SCAC codes for all ocean carrier partners and ensure these identifiers are linked to individual shipment records in their logistics systems. At the same time, importers should subscribe to maritime tracking services that collect and archive vessel ADS-B or AIS coordinates throughout each voyage. These datasets allow importers to verify that vessels followed planned routes, adhered to expected schedules, and delivered services consistent with contractual commitments. By joining freight spend data with vessel tracking records, importers can identify inefficiencies, delays, or service failures that may have contributed to demurrage, detention, or other unanticipated costs.
To support consistent and transparent reporting, importers should adopt a standard template for freight spend analysis. The template should include sections for total annual ocean freight spend, broken down by carrier (SCAC), route, and container type. It should present comparisons between invoiced rates and FMC benchmark rates, highlight variances, and document the root cause of significant discrepancies. The template should also incorporate a section that maps freight spend to vessel ADS-B coordinates, providing a factual basis for analyzing service levels and identifying patterns of delay or inefficiency. These reports not only help importers meet internal governance standards but also demonstrate a commitment to compliance with OSRA’s transparency objectives.
Importers should also consider engaging their freight forwarders and third-party logistics providers in these transparency efforts. By requiring partners to adopt similar data practices and share relevant rate and tracking data, importers can extend visibility across their end-to-end shipping operations. Contractual provisions mandating adherence to OSRA billing standards, use of FMC data benchmarks, and participation in freight transparency initiatives can help align the interests of all supply chain partners. These measures can further protect importers from unfair charges and promote accountability throughout the shipping process.
OSRA’s transparency provisions are likely to shape ocean freight practices for years to come. As regulators, importers, and carriers adapt to the new rules, technology and data integration will play a central role in ensuring compliance and unlocking the benefits of a fairer shipping market. Importers that proactively adopt OSRA-aligned data practices, benchmark shipping costs using FMC open data, and develop comprehensive freight spend reports will be well-positioned to manage risk, control costs, and strengthen their supply chain resilience in a dynamic global trade environment.