Consolidated Cargo Storage Fees for Imports at CFS
Interlink編集部What Are CFS Storage Charges for Import LCL Cargo?
CFS storage charges for import LCL cargo are storage fees incurred when imported LCL cargo is received at a CFS in Japan, devanned, and sorted but remains uncollected beyond the applicable free storage period.
Unlike FCL cargo, which is received and picked up from the CY on a container basis, LCL cargo is devanned from a consolidated container, sorted by House B/L or individual cargo units, and only released from the CFS after completing the D/O procedures, obtaining the Import Permit, settling fees, scheduling gate-out, and fulfilling other conditions.
Therefore, for import LCL shipments, it is necessary to confirm not only the vessel’s arrival date but also the CFS in-gate date, devanning completion date, cargo availability date, expiration of the free storage period, and the actual gate-out date.
The start date for CFS storage charges, number of free days, billing units, minimum fees, and surcharges for special cargo vary depending on the CFS, port, NVOCC, rate schedules, and cargo conditions. There is no uniform calculation method applicable to all import LCL cargo.
Scope Covered in This Article
| Item | Contents Covered in This Article | Contents Covered in Other Articles |
|---|---|---|
| CFS Storage Charges | Organizes the basic structure, start date, and charging conditions of storage fees incurred for import LCL cargo. | The detailed breakdown of overall CFS charges is handled in the “CFS Charge” article. |
| Free Storage Period | Clarifies how to confirm the free storage period, its end date, and the treatment of business days. | Container demurrage and detention are covered in related articles. |
| Devanning and Cargo Availability Date | Explains the relationship between the CFS in-gate date, devanning completion date, cargo pickup date, and storage charges. | The devanning process is discussed in the article “What Is Devanning Work for Co-loaded Cargo?” |
| Arrival Notice | Organizes the relationship between the receipt date of the Arrival Notice and the occurrence of storage charges. | Investigation of notification delays and response procedures is covered in the article “Delay of Arrival Notice for Import LCL Cargo.” |
| D/O Procedures | Addresses the cost impact when cargo cannot be released because D/O procedures remain incomplete. | The legal and practical functions of a D/O are discussed in the “D/O” article. |
| Import Permit | Organizes the relationship between storage charges and customs delays caused by documentation deficiencies, customs inspections, and other regulatory checks. | Import declarations and customs inspections are covered in customs-related articles. |
| Pickup Reservation | Organizes storage charges incurred when reservation slots cannot be secured or vehicle arrangements are delayed. | Specific pickup procedures are handled in the article “CFS Pickup for Import LCL Cargo.” |
| Cost Responsibility | Organizes the criteria for allocating costs arising from Arrival Notice, customs clearance, D/O, CFS, and delivery-related causes. | Legal liability and claim procedures for individual cases are covered in carrier-liability and claims-related articles. |
| Cargo Incidents and Insurance | Addresses the points to confirm when storage periods are extended because of a cargo incident or investigation. | Coverage decisions and marine cargo insurance claims are handled in related cargo-insurance articles. |
Basic Structure of CFS Storage Charges and the Free Storage Period
A CFS may provide a period during which no storage charge is imposed after cargo has been received and devanned. In practice, this period is commonly called the free storage period or free time.
However, whether a free storage period is provided, its duration, its starting date, and whether Saturdays, Sundays, and public holidays are included vary according to the CFS and its tariff.
It is therefore inappropriate to assume that free time is always a fixed number of days. The Arrival Notice, applicable CFS tariff, and information provided by the NVOCC or Japanese agent must be checked.
| Item to Confirm | Possible Criteria | Documents to Check | Practical Notes |
|---|---|---|---|
| Start Date for Storage Charges | CFS in-gate date, devanning completion date, cargo availability date, or another specified date | Arrival Notice, CFS tariff, in-gate record | The vessel arrival date and the start date for storage charges may not coincide. |
| Free Storage Period | Calendar days, business days, or another individually specified period | Tariff, Arrival Notice, agent’s notification | Confirm whether weekends and public holidays are included. |
| Charge End Date | Gate-out date, day before gate-out, or a CFS-specified cutoff time | Gate-out record, billing details, tariff | Confirm whether the gate-out date itself is chargeable. |
| Charging Unit | RT, weight, volume, package count, pallet count, or number of days | Tariff, quotation, billing details | Confirm minimum charges and rounding rules. |
| Special Cargo | Hazardous cargo, overlength cargo, heavy cargo, temperature-controlled cargo, and similar cargo | Special-cargo tariff, acceptance conditions | Additional surcharges may apply separately from standard storage charges. |
| Holidays and Non-Working Days | Whether CFS non-working days are included in the chargeable period | Business-day notices, tariff | Before and after consecutive holidays, actual gate-out opportunities may be limited even during the free period. |
Difference Between CFS Storage Charges and Demurrage or Detention
CFS storage charges for import LCL cargo are separate from demurrage and detention charges that commonly apply to containers in FCL transportation.
| Charge | Main Subject | Main Location or Situation | Contact Point | Notes |
|---|---|---|---|---|
| CFS Storage Charges | LCL cargo after devanning | Cargo stored by shipment unit inside a CFS | CFS, NVOCC, Japanese agent | Confirm the start date, free storage period, and billing unit. |
| Demurrage | Import container | Container retained at a terminal or similar facility | Shipping line, terminal | This primarily arises in FCL transportation. |
| Detention | Container equipment after gate-out | Container not returned within the permitted period | Shipping line, container lessor or manager | Confirm the empty-container return deadline. |
| CFS Handling Charge | LCL cargo | In-gate, devanning, sorting, and gate-out operations | CFS, NVOCC | This is an operational charge separate from storage charges. |
| Additional Gate-Out or Handling Charge | Oversized, heavy, or special cargo | Gate-out or handling requiring special equipment or procedures | CFS, cargo-handling company | This may arise independently of the storage period. |
Why the Start Date for Storage Charges Must Be Confirmed
For import LCL cargo, the vessel arrival date alone is insufficient to determine when storage charges begin or when the cargo becomes available for pickup.
After the vessel arrives, the container is transferred from the terminal to the CFS, devanned, and sorted by House B/L or cargo unit. If damage, shortage, or a marking discrepancy is identified, additional inspection time may also be required.
Depending on the applicable tariff, the free storage period may be calculated from the CFS in-gate date, devanning completion date, cargo availability date, or another designated date. The storage-charge start date must therefore not be estimated solely from the ETA.
The following dates should be confirmed:
- Actual vessel arrival date
- Container in-gate date at the CFS
- Scheduled devanning date
- Actual devanning completion date
- Cargo sorting completion date
- Cargo availability date
- Start and end dates of the free storage period
- Import Permit date
- D/O procedure completion date
- Pickup reservation date
- Actual CFS gate-out date
Main Causes of CFS Storage Charges
| Main Cause | Verification Documents | Key Points for Assessment | Initial Response | Division of Roles with Related Articles |
|---|---|---|---|---|
| Delay in Arrival Notice | Issue date, transmission records, receipt date, CFS in-gate information | Could the cargo have been released within the free storage period if the notice had arrived on time? | Confirm the issuer, Japanese agent, and transmission route. | Detailed causes of delay are covered in “Delay of Arrival Notice for Import LCL Cargo.” |
| Japanese Agent Is Unknown | House B/L, Master B/L, Booking Confirmation | Who managed the D/O and cargo release in Japan? | Inquire with the overseas NVOCC or prime freight forwarder. | Procedures for identifying the agent are covered in “Delay of Arrival Notice for Import LCL Cargo.” |
| Delay in D/O Procedures | D/O application date, invoice, payment record, required documents | Whose procedure, document submission, or payment remained incomplete? | Confirm all outstanding conditions with the D/O issuer. | The D/O itself is covered in the “D/O” article. |
| Insufficient Customs Documents | Invoice, Packing List, B/L, permits and licences | During what period did the missing documents actually prevent the import declaration? | Identify the missing documents and their expected submission dates. | Declaration documents are covered in customs-documentation articles. |
| Delay in Import Permit | Declaration date, customs inquiries, inspection records, Import Permit | Was the delay attributable to ordinary examination, missing information, inspection, or another regulatory requirement? | Obtain the current status and unresolved issues from the customs broker. | Customs examinations and inspections are covered in customs-related articles. |
| Pickup Reservation Cannot Be Secured | Reservation request date, CFS response, available reservation slots | Was a usable slot available during the free storage period? | Secure the earliest available slot and check for cancellations. | Pickup procedures are covered in “CFS Pickup for Import LCL Cargo.” |
| Delivery Destination Cannot Accept the Cargo | Delivery appointment, acceptance date, delivery instructions | Could the cargo have been removed from the CFS and temporarily stored elsewhere? | Consider transfer to another warehouse or amendment of the delivery date. | Inland-delivery costs are covered in related inland-delivery articles. |
| Cargo Damage or Shortage | Incident report, photographs, tally record, handover record | Was continued storage necessary for inspection or preservation of evidence? | Notify the CFS, carrier, insurer, and other relevant parties. | Detailed incident response is covered in cargo-incident articles. |
| CFS Operations or Congestion | Planned devanning date, actual devanning date, operational notices | On what date did the cargo actually become available for pickup? | Obtain a written or otherwise recorded response from the CFS. | CFS operations are covered in related devanning articles. |
Division of Roles Concerning Delayed Arrival Notices
When an Arrival Notice is not received and CFS storage charges are incurred, this article addresses the start date for storage charges, the free storage period, the chargeable days, and the resulting effect on cost responsibility.
The reasons why an Arrival Notice was not issued, why it was sent to the wrong recipient, why the Japanese agent could not be identified, and how information moved between the House B/L and Master B/L are covered in detail in “Delay of Arrival Notice for Import LCL Cargo.”
Rather than duplicating that explanation, this article uses the following facts when assessing storage charges and cost responsibility:
- Date and time when the Arrival Notice was issued
- Actual transmission date and time
- Recipient to whom the notice was transmitted
- Date and time when the importer or customs broker received the notice
- Date and time when the Japanese agent received the cargo information
- CFS in-gate date
- Date when the cargo became available for pickup
- Whether cargo-release procedures were initiated promptly after receipt of the notice
D/O Procedures and CFS Storage Charges
In import LCL transportation, even if the Import Permit has been issued, the cargo may still not be released from the CFS if the D/O procedures, settlement of destination charges, or other cargo-release conditions remain incomplete.
The D/O issuer or processing contact may be the NVOCC, House B/L issuer, co-load partner, or Japanese agent. The party’s name alone is not determinative. It is necessary to confirm who is the contracting party under the House B/L and who manages cargo release in Japan.
When reviewing storage charges resulting from a delay in D/O procedures, the D/O application date, date of submission of required documents, invoice date, payment date, and date on which the D/O could have been issued should be arranged chronologically.
Import Permit and CFS Storage Charges
To release import LCL cargo from a CFS, it is generally necessary to obtain an Import Permit and satisfy all other applicable cargo-release conditions.
If the Import Permit is delayed because of incomplete documents, product-description verification, customs inspection, customs valuation, origin verification, or another regulatory procedure, the storage period at the CFS may also be extended.
Food products, chemicals, medical devices, cosmetics, electrical appliances, hazardous materials, and other regulated goods may require additional checks or permits depending on the cargo. However, the fact that a product belongs to a particular category does not in itself mean that customs clearance will be delayed.
When determining responsibility for storage charges, the ordinary customs-processing period should be distinguished from delays caused by incomplete documentation, an error or omission by the importer, late declaration by the customs broker, inspection, or another regulatory requirement.
Pickup Reservations and CFS Storage Charges
Some CFS facilities require an advance reservation for cargo pickup. Even after the Import Permit and D/O procedures have been completed, the cargo may not be collected until a reservation slot is secured.
During busy periods, before consecutive holidays, during port congestion, or when cargo is oversized, heavy, or requires special handling, an earlier reservation than usual may be necessary.
If storage charges arise because of a pickup-reservation issue, the reservation-request date, the earliest slot initially offered by the CFS, the end of the free storage period, and the availability of alternative slots should be confirmed.
Even where a reservation request was submitted within the free storage period, the earliest date offered by the CFS may fall after that period. This fact should be documented, but it does not automatically result in a waiver of the storage charges.
Points to Confirm When Calculating CFS Storage Charges
The method for calculating CFS storage charges varies according to the tariff, cargo conditions, and CFS. When checking an invoice, the following elements should be reviewed in addition to the unit rate.
| Calculation Element | Details to Confirm | Typical Issue | Where to Confirm |
|---|---|---|---|
| Start Date | The date from which storage days are counted | The vessel arrival date is incorrectly used as the start date. | CFS, NVOCC, Japanese agent |
| Free Storage Period | Number of free days and whether they are calendar days or business days | The treatment of weekends and holidays has not been checked. | Tariff, Arrival Notice |
| Chargeable Days | Whether the gate-out date is included and how partial days are treated | The billed number of days differs from the period assumed by the cargo owner. | CFS billing department |
| Charging Unit | RT, weight, volume, package count, or pallet count | It is unclear whether weight or volume was used. | Tariff, billing details |
| Minimum Charge | Whether a minimum charge applies to small shipments | An estimate based solely on the unit rate does not match the invoice. | Tariff |
| Tiered Rates | Whether the rate increases or changes after specified periods | The same rate is incorrectly applied to the entire storage period. | Tariff |
| Special-Cargo Surcharges | Additional conditions for hazardous, overlength, heavy, or temperature-controlled cargo | The cost is budgeted using the standard-cargo rate. | CFS, NVOCC |
| Consumption Tax and Other Tax Treatment | Tax classification, disbursements, and any tax-exempt items | Only the total invoice amount is reviewed without checking the breakdown. | Billing party |
RT and CFS Storage Charges
RT may be used as the billing unit for CFS storage charges and other LCL-related costs. RT generally represents a Revenue Ton, under which the chargeable quantity is determined by comparing weight and measurement under the applicable tariff.
Some current LCL tariffs treat 1,000 kilograms or 1 CBM, whichever produces the greater chargeable quantity, as 1 RT. Other tariffs may use a Measurement Ton based on 40 cubic feet, approximately 1.133 CBM.
It must therefore not be assumed that 1 RT always equals 1 CBM. The definition stated in the tariff actually applicable to the shipment must be checked.
| Check Item | What to Confirm | Common Mistake | Action |
|---|---|---|---|
| Weight Basis | How many kilograms are treated as 1 RT | Gross weight is confused with chargeable weight. | Check the W/M provisions in the tariff. |
| Measurement Basis | Whether 1 CBM or another measurement conversion is used | It is assumed that every tariff uses 1 CBM. | Confirm the tariff’s definition of Measurement Ton. |
| Selection Criterion | Whether the greater result based on weight or measurement is used | The smaller result is incorrectly used. | Verify the calculation of the chargeable quantity. |
| Rounding Method | Whether decimals are rounded up, rounded normally, or calculated without rounding | The cargo owner’s calculation differs from the invoiced quantity. | Check the rounding rule in the tariff. |
| Minimum Charge | Whether a minimum quantity, such as 1 RT, applies | A small shipment is calculated only by its actual weight or volume. | Check both the minimum charge and the minimum billable quantity. |
Determining Cost Responsibility by Cause
When CFS storage charges are incurred, whether the CFS invoice is correctly calculated and who should ultimately bear the cost are separate questions.
Even where the CFS has correctly invoiced the charges under its tariff, cost responsibility may still require allocation among the parties if the storage resulted from a delayed Arrival Notice, an incomplete D/O procedure, missing importer documents, or delayed action by another party.
| Cause | Verification Documents | Criteria for Cost Responsibility | Notes |
|---|---|---|---|
| Delayed Issuance or Transmission of the Arrival Notice | Issuance timestamp, transmission record, receipt date, earliest pickup date | Could the cargo have been picked up within the free storage period if the notice had been timely? | A delayed notice alone does not automatically establish responsibility for the full charge. |
| Incorrect Contact Information | B/L Draft, correction history, final B/L | Who supplied the incorrect information, and who had an opportunity to correct it? | The cause may result from combined errors by the exporter, importer, and B/L issuer. |
| Delay in D/O Procedures | Application date, invoice, payment record, issuance date | Who was required to submit the documents or payment, and by what date? | Distinguish processing delay by the issuer from delay by the applicant. |
| Missing Importer Documents | Document-request date, receipt date, declaration date | During what period did the missing documents actually prevent the declaration or Import Permit? | Separate this period from any overlapping Arrival Notice delay. |
| Customs Inspection or Other Regulatory Checks | Customs notices, inspection records, permit documents | Was the delay part of ordinary administrative processing or caused by an error or omission by a party? | The fact that an inspection occurred does not itself establish negligence. |
| CFS Devanning or Handling Delay | Scheduled date, actual date, cargo-availability notification | During what period was the cargo actually available for pickup? | Check the tariff if storage charges were imposed during a period when pickup was impossible. |
| No Pickup Reservation Slot Available | Reservation-request record, CFS response, earliest available slot | Was the request submitted promptly, and were alternative slots available? | Lack of an available slot does not automatically justify a waiver or reduction. |
| Delivery Destination or Delivery Provider Scheduling | Delivery appointment, vehicle arrangement, earliest acceptance date | Could the cargo have been transferred from the CFS to another warehouse? | Compare the additional transport cost with the increasing storage charges. |
| Cargo-Incident Verification | Incident report, photographs, inspection record, insurer’s instructions | Was continued storage reasonably necessary to inspect the cargo or preserve evidence? | Preserve the evidence and promptly notify insurers and other relevant parties. |
The cause of storage is not necessarily singular. Periods attributable to an Arrival Notice delay, missing customs documents, customs examination, incomplete D/O procedures, or an unavailable pickup slot should be separated and arranged chronologically.
While cost responsibility remains under discussion, reasonable measures should still be taken to release the cargo or move it to alternative storage as early as practicable so that the charges do not continue to increase.
Scope of Freight Forwarder Involvement and CFS Storage Charges
The five classifications used in this article are not established by law or industry-wide consensus. They serve as an analytical framework within this series to clarify the scope of freight forwarder involvement.
| Standard Five Classifications | Main Involvement Regarding CFS Storage Charges | Responsibilities to Be Confirmed | Points to Check When Storage Charges Occur |
|---|---|---|---|
| Simple Intermediary | Forwards the Arrival Notice, tariff, or CFS information. | Extent to which receipt and transmission of information were entrusted | Confirm when the information was received, when it was forwarded, to whom it was sent, and what information was included. |
| Cargo Transportation Service Provider | Provides arrival information and cargo-release procedures as part of the transportation service. | Transportation contract, quotation terms, applicable conditions, and agreed cost provisions | Confirm the contractual point of contact and the party actually arranging the CFS operations. |
| NVOCC / House B/L Issuer | Issues the House B/L and arranges ocean transportation and cargo release in Japan. | House B/L terms, Japanese-agent arrangements, D/O procedures, and destination charges | Confirm which contractual party is responsible for providing information and explanations to the cargo owner. |
| Door-to-Door Single Contractor | Coordinates customs clearance, CFS gate-out, and inland delivery as an integrated service. | Scope of the integrated contract, subcontracting, additional-charge provisions, and liability limitations | Confirm at which stage of the integrated service the storage charges arose. |
| Agent/Coordinator for Specific Operations | Performs specified tasks such as obtaining the D/O, making a gate-out reservation, or confirming the CFS. | Tasks expressly entrusted, applicable deadlines, and work outside the mandate | Confirm the instructions, agreed deadline, action taken, and completion report. |
When the prime freight forwarder issues the House B/L and acts as the contractual transportation provider, its accountability for destination charges and cargo release should be considered under the NVOCC / House B/L Issuer classification.
By contrast, a service provider engaged only to forward the Arrival Notice or arrange a gate-out reservation is not necessarily responsible for CFS storage charges, customs-clearance progress, D/O procedures, or delivery-destination coordination outside the entrusted task.
Contracting Carrier and Actual Carrier are legal or contractual status concepts and do not replace the Standard Five Classifications used in this article.
Practical operations such as devanning, CFS storage, D/O processing, customs clearance, gate-out reservations, and inland delivery do not by themselves constitute a sixth classification.
Common Misunderstandings
| Misunderstanding | Actual Consideration | Practical Notes |
|---|---|---|
| Storage charges always begin on the vessel arrival date. | The start date may be the CFS in-gate date, devanning completion date, cargo availability date, or another date specified in the tariff. | Check the tariff and actual CFS operational dates. |
| CFS free time is the same as demurrage. | CFS storage charges apply to cargo after devanning, while demurrage primarily concerns containers. | Do not confuse the cost structures of LCL and FCL transportation. |
| The cargo can always be picked up on the day the Import Permit is issued. | Release may still be prevented by incomplete D/O procedures, unpaid charges, or a missing pickup reservation. | Confirm customs requirements and CFS release conditions separately. |
| If the Arrival Notice is delayed, the issuer must bear all storage charges. | Cost responsibility depends on the contract, causation, actions taken after receipt, and other concurrent causes. | Prepare a timeline of the issue date, receipt date, Import Permit date, and gate-out date. |
| Storage charges are always calculated per 1 CBM. | The applicable unit may be RT, weight, measurement, package count, or another tariff unit. | Confirm the RT definition and any minimum charge. |
| The free storage period is always calculated in business days. | The tariff may instead use calendar days. | Confirm whether weekends and public holidays are included. |
| Storage charges are automatically waived whenever the CFS is congested. | CFS congestion and entitlement to a charge waiver are separate issues. | Check the cargo-availability date, reservation-request date, and applicable tariff. |
| CFS storage charges are always covered by marine cargo insurance. | Ordinary storage charges differ from physical loss of or damage to the cargo and are not necessarily covered. | Confirm the cause of the charge and the applicable policy terms. |
| Paying the storage charges means accepting final responsibility. | Payment required to obtain cargo release can be treated separately from the final allocation of the cost. | Record any reservation of rights and the basis on which payment was made. |
Decision Checklist
| Check Timing | Party to Confirm With | Items to Confirm | Actions if Issues Arise |
|---|---|---|---|
| Before Vessel Arrival | Japanese Agent, Prime Freight Forwarder | Arrival Notice issuer, planned receiving CFS, ETA | Confirm the Japanese contact point before shipment. |
| Upon Receipt of the Arrival Notice | Issuer, Japanese Agent | Free storage period, start date, CFS, D/O conditions | If these details are absent, obtain written confirmation. |
| Before and After Devanning | CFS, Japanese Agent | CFS in-gate date, devanning completion date, earliest pickup date | Record scheduled dates and actual dates separately. |
| Before Import Declaration | Importer, Customs Broker | Invoice, Packing List, licences, permits, and other required documents | Identify missing documents and their acquisition deadlines. |
| During D/O Procedures | NVOCC, Japanese Agent | Application method, required documents, charges, and payment conditions | Resolve each outstanding requirement promptly. |
| After the Import Permit Is Issued | Customs Broker, CFS | D/O, cargo-release status, and gate-out reservation | Do not assume that the Import Permit alone permits immediate pickup. |
| When Making a Gate-Out Reservation | CFS, Delivery Provider | Earliest available date, vehicle requirements, and handling conditions | Prioritize securing a slot within the free storage period. |
| When Storage Charges Are Incurred | CFS, Billing Party | Tariff, start date, chargeable days, RT, and minimum charge | Obtain the calculation basis and detailed invoice breakdown. |
| When Allocating Cost Responsibility | Contractual Counterparty, Related Parties | Cause, contract, mandate, chronology, and causal relationship | Separate the relevant periods by cause and negotiate on the basis of records. |
| When a Cargo Incident Is Involved | CFS, Carrier, Insurance Company, Insurance Agent or Broker | Incident details, photographs, handover records, and notification deadlines | Preserve evidence before gate-out, disposal, or alteration of the cargo. |
Example 1: The Devanning Completion Date Was Mistakenly Treated as the Start Date
The importer believed that the free storage period began when devanning was completed and continued for several days. The applicable tariff, however, calculated the free storage period from the day after the CFS in-gate date.
Because the container had entered the CFS shortly after the vessel arrived, the free storage period ended earlier than the importer expected. Storage charges had therefore accrued by the time the cargo was collected.
The tariff start date, actual CFS in-gate date, devanning completion date, and statements in the Arrival Notice should first be compared. If only the importer’s understanding differed from the tariff, the invoice is not necessarily incorrect.
If the Arrival Notice or another prior notification expressly stated a different start date, the consistency between that information and the actual billing conditions must also be examined.
Example 2: Storage Charges Increased Because No Pickup Slot Was Available
The Import Permit and D/O procedures were completed during the free storage period, but all CFS pickup slots were occupied. The earliest available reservation date fell after the free period expired.
The parties should verify when the reservation request was submitted, the earliest date offered by the CFS, whether a cancellation or alternative time slot was available, and the actual pickup date.
The assessment differs depending on whether the importer or delivery provider submitted the request late or submitted it on time but no CFS slot was available.
The absence of an available slot does not automatically exempt the storage charges. The tariff and CFS practices should be reviewed, after which the relevant parties may need to negotiate the final cost allocation.
Example 3: Arrival Notice Delay and Missing Customs Documents Overlapped
The Arrival Notice was received several days late. During the same period, the corrected Invoice required for the import declaration had also not been received.
Even if the Arrival Notice had arrived on time, the import declaration could not have been completed while the Invoice remained unavailable. It would therefore be inappropriate to attribute the entire storage period solely to the Arrival Notice delay.
The period during which the Arrival Notice was outstanding, the period during which the customs documents were incomplete, and the period after issuance of the Import Permit during which the gate-out reservation remained incomplete should be arranged separately.
Where several causes overlap, the entire storage charge may not be recoverable from a single party. The actual effect of each cause on the gate-out date must be established.
Points to Confirm to Prevent Storage Charges
To reduce the risk of CFS storage charges, the parties should not merely wait for the Arrival Notice after the cargo arrives. The Japan-side cargo-release structure should be confirmed before vessel arrival.
- Arrival Notice issuer
- Name and contact details of the Japanese agent
- House B/L number and Master B/L number
- D/O issuer and issuance procedure
- Scheduled receiving CFS
- Latest ETA
- Scheduled CFS in-gate date
- Scheduled devanning date
- Cargo availability date
- Free storage period
- Start date for storage charges
- RT definition and minimum charge
- Documents required for the import declaration
- Possible customs inspection or other regulatory procedure
- Whether a gate-out reservation is required
- Date from which a gate-out reservation can be made
- Special conditions for oversized, heavy, hazardous, or other special cargo
- Delivery destination’s earliest acceptance date
Relationship with Cargo Insurance and Freight Forwarder’s Liability Insurance
CFS storage charges differ from physical loss of or damage to the cargo. Ordinary storage charges arising solely from a delayed Arrival Notice, missing customs documents, delayed D/O procedures, or cargo owner-related circumstances are not necessarily covered by marine cargo insurance.
If a cargo incident occurs and the CFS storage period is extended for inspection, survey, evidence preservation, or investigation of the cause, the nature of the storage charges, their causal relationship with the incident, and the applicable insurance terms must be examined.
If a freight forwarder is required to bear CFS storage charges because of an error in providing information, arranging the D/O, making the gate-out reservation, or arranging customs clearance, the claim may fall within the scope of freight forwarder’s liability insurance. Coverage depends on contractual liability, the entrusted operations, applicable conditions, exclusions, type of loss, notification timing, deductible, and other policy terms.
Before admitting liability, agreeing to a settlement, promising to bear the cost, or making payment, the freight forwarder should consult its insurance company, insurance agent, or insurance broker.
Summary
When reviewing CFS storage charges for import LCL cargo, it is necessary to confirm not only the vessel arrival date but also the CFS in-gate date, devanning completion date, cargo availability date, end of the free storage period, and actual gate-out date.
CFS storage charges may arise because of delays involving the Arrival Notice, D/O, Import Permit, CFS operations, gate-out reservation, inland delivery, or delivery-destination arrangements.
When checking the invoiced amount, confirm the start date, free storage days, chargeable days, definition of RT as Revenue Ton, minimum charge, tiered rates, rounding rules, and surcharges for special cargo.
Whether the invoice is correct under the tariff and who should ultimately bear the cost are separate questions. Where several causes exist, the period attributable to each cause should be arranged chronologically.
For procedures to identify the Arrival Notice route and Japanese agent, refer to “Delay of Arrival Notice for Import LCL Cargo.” For CFS gate-out procedures, refer to “CFS Pickup for Import LCL Cargo.”
This article explains general practical matters concerning import LCL cargo and does not determine legal liability, cost responsibility, or insurance coverage for an individual case. Actual decisions require review of the tariff, Arrival Notice, quotation, transportation contract, House B/L terms, standard trading conditions, operating instructions, communication records, and applicable insurance policy.
