OSRA 2022 final rule in effect/ FMC fines MSC $22.67M/ 30 / 30 / 30 dispute window/ 23% of reefer bills overcharged/ Contingency · pay only on recovery/ Mid-market shippers · 50–5,000 containers/yr/ OSRA 2022 final rule in effect/ FMC fines MSC $22.67M/ 30 / 30 / 30 dispute window/ 23% of reefer bills overcharged/ Contingency · pay only on recovery/ Mid-market shippers · 50–5,000 containers/yr/
Ocean Freight Invoice Recovery

Stop paying
invoices that
aren't legally enforceable.

Under OSRA 2022's final rule (eff. May 28, 2024), every D&D invoice must carry 13 mandatory data elements. Miss one — and the shipper has no legal payment obligation. We audit, dispute, and recover. You pay only on recovery.

Request a Free Audit See how it works
catch a charge
Contingency-BasedNo upfront fees
30-day + 3-yearCarrier + FMC windows
OSRA Final Rule13 mandatory elements
Maersk + MSC · Top D&D risk carriers
OSRA 2022 · 46 CFR 541 If your carrier's invoice is missing any of the 13 required elements, the bill is unenforceable. Read the rule
The Problem

D&D charges are a tax on shipper inertia.

Carriers stack invoices that violate federal billing rules, mis-bill reefer plug-ins, and double-charge on container moves. Most shippers either pay them or dispute them informally inside the 30-day window — and lose. The rules changed in 2024. The leverage moved.

23%
of reefer plug-in bills found to be overcharges
FMC's 2024 investigation into MSC reefer billing found systemic overcharging across thousands of plug-in events.
Source · FMC Docket 23-08
$22.67M
civil penalty assessed against MSC
January 2026 FMC enforcement action — the largest D&D-related civil penalty in agency history.
Source · FMC Press Release, Jan 2026
30 / 30 / 30
the carrier billing window
Carriers must invoice within 30 days of the billable event. Shippers have 30 days to dispute. Carriers have 30 days to respond. Outside this window, FMC charge complaints extend recovery rights to 3 years.
Source · 46 CFR 541.6 · 46 USC 41310
Case Study · January 2026

FMC vs. MSC:
$22.67M.

The Federal Maritime Commission's enforcement action against MSC Mediterranean Shipping found 23% of audited reefer bills contained overcharges — systemic, traceable, and recoverable.

The case validated what shippers have known for years: carrier billing is broken, and the regulator is now in the room.

Volta Orange's audit engine targets the exact pattern types FMC surfaced — duplicate moves, missing exemption codes, reefer plug-in miscalculation, and OSRA documentation gaps.

Source · FMC enforcement filing, Docket 23-08

How a Volta Orange engagement runs.

We don't sell software. We run a structured audit-and-recovery cycle on your last 90 days of carrier invoices, then keep auditing forward on retainer. Contingency on recovered dollars. No platform fees.

01
Day 0
Discovery + invoice intake
30-minute call. You forward 90 days of D&D, detention, and accessorial invoices from your top 3 carriers. NDA signed. Engagement letter executed.
02
Week 1
Pattern-matched audit
Every invoice is run against the OSRA 13-element checklist, reefer plug-in calculation logic, duplicate-move detection, and free-time validation. Findings logged with carrier, container, dollar value, and dispute basis.
03
Week 2
Findings report + dispute drafting
You receive a categorized recovery worksheet — total exposure, recoverable estimate, and per-invoice dispute letter drafts ready for your signature or ours.
04
Week 3+
Filing + recovery
In-window invoices get filed directly with Maersk, MSC, Hapag-Lloyd, CMA CGM, and ONE through their dispute portals. Out-of-window invoices with documented overcharges get filed as FMC charge complaints under 46 USC 41310 — the 3-year recovery window. Goodwill credit claims pursued where appropriate.
05
Ongoing
Forward audit retainer
Every new invoice gets audited inside the 30-day window. You stop paying invalid charges before they become recovery cases.
Port operations · GPA / Savannah
Built For

Mid-market shippers carrying real container volume.

We're built for shippers between 50 and 5,000 containers per year. Big enough to lose six and seven figures to billing errors. Small enough that no one is auditing your carrier file.

Food & Beverage
Reefer-heavy shippers exposed to plug-in miscalculation and temperature-event misbilling.
Reefer · OSRA · Reefer Plug
Specialty Retail
Seasonal import surges magnify D&D exposure during peak holiday and back-to-school cycles.
D&D · Free time · Duplicate moves
Building Materials
Heavy container weight, complex terminal handling, and accessorial line items prone to duplicate billing.
Accessorials · OSRA
Household Goods
Furniture, appliance, and home goods importers with high SKU/container ratios and complex deconsolidation.
D&D · Per-diem · Detention
Audit Coverage

The error patterns we hunt.

Phase 1 focuses on the three error categories that are fully automatable, federally enforceable, and routinely recoverable. The audit engine expands as case data accumulates.

01 · OSRA Compliance
13 mandatory elements
Every D&D invoice gets validated against the OSRA 2022 final rule. Missing carrier identification, missing free-time start, missing dispute contact — the invoice is unenforceable. We document, dispute, and recover.
02 · Duplicate Billing
Container move deduplication
We cross-reference container, ETD, and accessorial codes across the carrier file. Same gate-out, billed twice. Same chassis day, billed twice. Statistically common — and statistically recoverable.
03 · Reefer Overcharge
Plug-in calculation audits
The MSC pattern. Plug-in event logs reconciled against billed hours, dwell exemptions, and free-time entitlements. FMC's own data put the overcharge rate at 23%.
Founders

Built by a procurement & operations team.

Volta Orange was founded by Colby Knox — a procurement and program planning operator at a Tier-1 OEM — and Axel, a logistics-platform builder.

We're not freight forwarders. We're not an audit firm pivoting into tech. We're an execution-focused recovery team running a tight, repeatable cycle on the only invoices that matter: the ones the carrier wrote wrong.

Based In
Tuscaloosa, AL
Engagement Model
Contingency + retainer
Carrier Coverage
Maersk · MSC · Hapag · CMA · ONE
Status
Accepting founding clients
Founding Clients

Free 90-day audit. Three things delivered.

We're accepting a small number of founding clients to anchor the audit engine. Send us your last 90 days of carrier D&D invoices and we'll run the full audit at no cost. Here's what you get back.

  • In-window recovery (last 30 days): filed directly with the carrier · highest recovery rate
  • Out-of-window claims (30–90 days): FMC charge complaints + goodwill credit pursuit · 3-year statute
  • Quantified leak report: documented overcharge rate across the 90 days · basis for the forward audit retainer
  • Contingency on recovered dollars · no recovery, no fee

No commitment. We'll respond within one business day.

Request received.

We'll be in touch within one business day to schedule the audit kickoff.

Or Book Directly

30 minutes. No pitch deck.

Pick a time and we'll walk through your last carrier invoice on the call. If we don't find a recoverable error, the call costs you nothing but 30 minutes.

Stop paying invoices that aren't legally enforceable.

Send us 90 days of your carrier invoices. We'll send you back a recovery worksheet.

Request a Free Audit catch a charge