FMC Rule 46 CFR §541  ·  Effective May 2024

Stop Paying Questionable D&D Charges.

PierTrace helps importers review D&D invoices, identify high-risk charges, and build the evidence your team needs to push back on carriers — before you pay.

Request a Pilot Audit See the process
◎ Currently onboarding a small number of importers for pilot audits. We work through each engagement closely to make sure the output is accurate and actionable — not automated noise.

// What PierTrace is

A Compliance-First
Audit Workflow.
Not Magic.

We extract and structure your D&D invoice data, check it against FMC Part 541 invoice-content and issuance-timing requirements, and surface the charges that look wrong — with timeline evidence added when the facts need support.

We hand you a complete package for each flagged charge: the evidence, the specific rule violated, and a draft letter ready to send. Your team sends it. The carrier responds to you directly. We're not in the middle of that conversation.

.

What this is

✓ A structured review of your D&D invoices against FMC Part 541 content and timing requirements, with supporting timeline evidence where it matters
✓ A ranked output of high-risk charges with evidence attached — ready for your team or broker to act on
✓ A complete evidence pack and draft letter for each flagged charge — everything needed to contact the carrier yourself

What this is not

✗ A fully automated system that disputes invoices without your review
✗ A guarantee that every charge flagged will be successfully recovered
✗ A replacement for your customs broker or trade attorney

// Process

How It Works

Start by forwarding invoices. We handle the heavy lifting and surface the exceptions. You stay in control of what happens next.

STEP 01
Forward Invoices
Send us your recent D&D invoices — typically the last 3–12 months. PDF, Excel, or CSV all work. No integrations or system access needed to start.
Any format from any carrier accepted
STEP 02
We Extract & Review
We parse and structure the invoice data — container numbers, free-time periods, billed amounts, party details — into a normalised audit record.
Human-reviewed for accuracy
STEP 03
Flag High-Risk Charges
Each invoice is checked first for FMC Part 541 content compliance and issuance timing. Timeline evidence is added only where the facts need support.
Part 541 audit first, timeline support second
STEP 04
Prepare Evidence
We draft dispute-ready evidence packs for flagged charges — including the specific rule violation or documented carrier delay behind each one.
Evidence cited, not just asserted
STEP 05
You Send It
You receive a ranked list of flagged charges — each with the specific evidence and a draft letter ready to go. Your team or broker sends it to the carrier. You stay in full control.
We prepare it. You send it.
MSC / INVOICE #MC-2026-114893
Container: MSCU7482910  ·  Port: Los Angeles
⚑ Under Review
CARRIER FREE-TIME END Mar 18  ← Queried
VESSEL ARRIVAL SUPPORT Mar 16 ✓
PORT CLOSED (Mar 17) Federal Holiday — may exclude
REQUIRED INVOICE ELEMENTS Missing required Part 541 content
BILLED PARTY CHECK Review against BOL consignee
DISPUTE CONTACT LISTED Yes ✓
Carrier billed
$9,800
Flagged for review
3 issues
⚑  Free-time period may be miscounted — supporting timeline evidence required
⚑  Missing required Part 541 invoice content — FMC compliance issue
⚑  Billed-party details should be verified against the original BOL
↳ Evidence pack + draft letter delivered to your team.
Your team sends it to the carrier directly.

// What You Get

Every Flag Is
Evidence-Backed.

We don't just flag charges that "look high." Each issue is traceable to a specific Part 541 requirement, a documented timing issue, or a billing inconsistency we can point to in writing.

That means when you or your broker contacts the carrier, you have something concrete to send — not just a complaint.

→ Required Part 541 invoice elements checked
→ §541.7 issuance timing checked against invoice dates
→ Vessel and terminal timeline cross-reference for harder cases
→ Port closure and holiday calendar overlay
→ Billed-party verification against Bill of Lading
→ Charges ranked by estimated value — highest priority first
→ Draft letter written and ready — your team sends it, in 5 minutes

// Fit

Who This Is Built For

We work with a specific type of importer. If this sounds like you, it's worth a conversation.

📦
Import Volume
500–20,000 TEU / Year
Large enough to have meaningful D&D exposure, small enough not to have a dedicated audit team. You're probably paying invoices without a systematic review process.
🏭
Product Categories
Goods with Long Dwell Times
Furniture, apparel, food/CPG, auto parts, consumer electronics, or industrial goods. Categories where seasonal spikes or customs delays create D&D exposure.
👤
Decision Maker
Logistics or Finance Lead
Import Manager, Director of Logistics, VP Supply Chain, or CFO. Someone who owns the freight cost line and has the authority to engage on invoice disputes.
Not the right fit (yet)
Very large enterprise importers with dedicated trade compliance teams and existing freight audit programs. Companies importing fewer than 500 TEU/year where D&D exposure is too small to justify the audit. Freight forwarders looking for a white-label resale product — we're not set up for that at this stage.

// Pilot Program — Limited Spots

Request a Live Audit.

Share some basic details and we'll confirm whether this is a good fit. If it is, we'll review your recent D&D invoices at no upfront cost, prioritize the most actionable charges, and prepare evidence packs and draft letters for the ones worth challenging. Your team or broker sends the disputes. We charge 10–15% only on amounts actually recovered.

✓ Request received

We'll review your details and reach out within 1–2 business days to confirm fit and next steps. If it's a match, we'll send you instructions for sharing your invoice data securely.

✓ No upfront cost    ·   ✓ You send every dispute yourself — we prepare the evidence    ·   ✓ We charge 10–15% only on amounts the carrier actually refunds

// 15-Minute Call

Talk to the Founder.

No sales pitch. No demo deck. A direct conversation about whether PierTrace is the right fit for your situation — and what we'd actually find in your invoices.

You'll speak directly with the founder. We'll be straight with you about what we do, what we don't do, and whether the audit is likely to surface anything meaningful for your account.

1
Tell us about your import volume — which carriers, roughly how many containers per year, and what your current D&D process looks like.
2
We'll confirm if it's a fit — honestly. If your volume or carriers aren't covered yet, we'll say so rather than waste your time.
3
If it is a fit — we agree on a simple process for sharing invoices and kick off your pilot audit within the week.
Currently onboarding
Pilot spots are limited. We take on a small number of new importers at a time to make sure every audit gets proper attention — not an automated report.
PT
PierTrace Founder
Data Engineer · D&D Audit Specialist
15 minutes
Select a date below
Google Meet (link sent on confirmation)
April 2026
Su
Mo
Tu
We
Th
Fr
Sa
Available times
— Enter your details to confirm the booking.
✓
Call Confirmed
— You'll receive a calendar invite and Google Meet link at your email shortly. See you then.

// Questions

Common Questions

How do you get access to our invoices?
We'll send you a secure upload link and a dedicated email forwarding address. You share invoices on your terms — no system integrations or credentials required to start. We sign an NDA before you share anything.
Is this automated or does a human review things?
Both. Software extracts and structures the data. A human reviews the flagged items before the report reaches you. Nothing is ever sent to a carrier by us — every communication with the carrier comes from you or your broker.
What makes a D&D charge disputable?
Mainly three things: the invoice is missing required Part 541 content, it was issued outside the timing requirements in §541.7, or the billed timeline does not match what actually happened. We document the specific basis for each flag, not just a dollar amount.
If we send the disputes ourselves, how does the 10–15% fee work?
Simple. When a carrier issues a credit or refund based on a charge we flagged, you let us know the amount recovered. We invoice you for 10–15% of that amount. No recovery, no invoice from us. We track which disputes came from our audit so there's no ambiguity about what counts.
Can we dispute charges ourselves, or do you do it?
You send every dispute yourself — or hand the package to your customs broker. We prepare everything: the evidence, the cited rule, the draft letter. Sending it typically takes your team under 5 minutes per charge. We don't file disputes on your behalf.
Which carriers do you cover right now?
We're actively building coverage across the major ocean carriers serving US import lanes. Confirm which carriers you use when you request the audit and we'll let you know exactly what we can cover for your account.
What if the carrier doesn't respond?
The dispute letter cites a specific FMC rule violation — not just a general complaint. Many carriers respond, but response times and outcomes vary. If yours doesn't, your customs broker or a freight attorney can escalate using the evidence pack.
What does "pilot program" mean exactly?
We're in early-stage operations — onboarding a small number of importers carefully rather than at scale. This means you get direct access to the founder, faster turnarounds, and a collaborative process. The tradeoff is that we're selective about who we take on.