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Receiving 101 · Freight

Four of the seven are decided before the bill exists.

A freight bill audit is seven checks, and three of them can be done from paperwork whenever you get round to it. The other four are settled at the loading bay, by somebody who has already gone home by the time the invoice arrives.

By Hamza RiveraFounder, DockCount

In short

  • A carrier has 60 days to pay, decline or settle a written overcharge claim, under 49 CFR § 378.8, and must give written reasons if it declines.
  • Two clocks, and the shorter one binds: 180 days to contest a bill at all, 18 months to sue over it.
  • File in writing with the carrier that collected the charges, with the freight bill attached.
  • The most common cause of a re-rating is a class derived from a measurement that left the pallet out.

The clocks

Eighteen months, and it runs both ways

Most pages about auditing freight bills are published by companies that audit freight bills, and they end in a contact form rather than in the two facts that decide whether a claim is worth filing. Both are in the primary sources and neither is hard to read.

49 U.S.C. § 14705(b) gives you eighteen months from when the claim accrues to begin a civil action to recover an overcharge; going to the Board or the Secretary by complaint instead stretches that to three years. And § 14705(a) gives the carrier the same eighteen months to come after you for charges. That symmetry is why a re-rating can arrive for a shipment you no longer remember.

But eighteen months is not the clock that usually decides it. 49 U.S.C. § 13710(a)(3) is shorter and binds first, in both directions. A carrier must issue any bill for charges in addition to those originally billed within 180 days of your receipt of the original bill to have the right to collect them, so a re-rating that turns up eight months later is worth reading that subsection about. And a shipper must contest a bill within 180 days of receiving it to keep the right to contest it at all. A bill filed unexamined in January is not contestable in September, whatever its merits.

Before contesting anything, ask for the authority. § 13710(a)(1) requires a carrier to supply, on request, a written or electronic copy of the rate, classification, rules and practices the charge is based on. That request is often the whole dispute.

The part almost nobody quotes is the procedure. 49 CFR Part 378 governs overcharge, duplicate payment and overcollection claims:

§ 378.3: file in writing

With the carrier that collected the charges. That carrier processes it. File with another carrier in the movement and they have 15 days to pass it on.

§ 378.4: send the freight bill

The claim must be accompanied by the bill, and should carry the rate or classification you say applied and the tariff authority for it.

§ 378.8: 60 days to answer

Pay, decline or settle within 60 days of receipt. If they decline or pay less, they must say why in writing, citing tariff authority or what the investigation found.

A written claim quoting § 378.8 is treated differently from an email asking about an invoice, and it costs nothing extra to send.

A flat line illustration of a printed invoice lying on a desk beside a plain calculator, with a hand holding a pen having just drawn a single short teal underline beneath one row of charges.
The money is almost never spread across the bill. It is one line, and usually the same line every month.

The seven checks

CheckAgainstSettled where
Freight classThe density of the wrapped unit as tenderedAt the bay
WeightThe bill of lading, and any reweigh certificateAt the bay
DimensionsThe measurements of the finished palletAt the bay
Accessorial chargesWhat was requested, and what was performedAt the bay
Rate and discountYour tariff or negotiated agreementIn accounts
Terms and party billedPrepaid, collect or third party on the BOLIn accounts
Duplicate paymentYour own payment historyIn accounts

The three in the right-hand column marked in accounts are the comfortable ones: the evidence is on your own systems and it will still be there next month. The four marked at the bay are the problem, and they are where the money is.

Why the class line is the one to check first

A re-rating for class is the single most common correction on a freight bill, and it is almost never a disagreement about the classification. It is a disagreement about what was measured, and NMFTA names the cause in its own guidance: forgetting to include pallet or packaging height.

We worked the arithmetic through elsewhere and it is worth repeating here. Six inches of pallet under a 40 inch load at 450 lb is the difference between 10.13 pounds per cubic foot and 8.80, which is the difference between class 92.5 on your paperwork and class 100 at the carrier’s dock. The bill arrives weeks later as a correction you cannot check, because the pallet has been broken down and put away.

So the first thing to do with a class re-rating is not to argue it. It is to put the dimensions you shipped into a freight class calculator and find out whether the carrier is right. Half the time they are, and the answer is to measure differently next month rather than to file a claim.

The lines nobody expected

Accessorial charges are the second most common surprise and the hardest to argue after the fact, because the question is not what the tariff says but what actually happened at a delivery nobody documented. Did the driver use a liftgate? Was it an inside delivery? Did the truck wait?

A carrier’s driver records those. Most receivers do not, which means the carrier has evidence and the buyer has a memory. We set out what the common accessorials are and which ones you can prevent separately, because it is a longer subject than a line on a checklist.

The part this company exists for

An audit is only as good as what was written down at the bay

Every one of the four checks marked at the bay has the same shape. The carrier holds a record made at the moment: a dimensioner reading, a driver’s note, a signed receipt. You hold whatever your receiving process happened to capture, which in most small companies is a signature on the carrier’s own paperwork.

So the audit that finds money is not the one done more carefully in accounts. It is the one where somebody, at the delivery, wrote down the dimensions of what went out, noted that the driver used a liftgate, and counted what came in against the order rather than against the delivery note. None of that takes long. All of it has to happen before the truck leaves, and none of it can be reconstructed afterwards.

That is also why an invoice for goods that arrived short is the worst of the four. Matching the invoice against what was received catches it, and only if the receiving record is independent of the supplier’s paperwork.

Questions

What is a freight bill audit?
Checking a carrier's invoice against what was actually agreed and what actually moved: the rate, the class, the weight and dimensions, the accessorial charges, the payment terms, and whether the shipment arrived complete. It is a pre-payment or post-payment review, and the money in it is usually in a small number of lines rather than spread evenly.
How long do I have to claim a freight overcharge?
Two answers, and the short one binds first. Under 49 U.S.C. § 13710(a)(3)(B) you must contest the bill within 180 days of receiving it to have the right to contest the charges at all. Separately, § 14705(b) gives you eighteen months to begin a civil action, running from when the claim accrues. If you take it to the Board or the Secretary by complaint instead of suing, that is three years. File the claim with the carrier long before either: the regulation that governs the process, 49 CFR Part 378, assumes a written claim rather than a phone call.
How long does a carrier have to answer an overcharge claim?
Sixty days. 49 CFR § 378.8 requires the processing carrier to pay, decline or settle each written claim within 60 days of receiving it, unless you have agreed an extension in writing. If it declines or settles for less than you claimed, it has to tell you in writing why, citing the tariff authority or what its investigation found. Silence past 60 days is worth chasing with the section quoted.
Who do I file a freight overcharge claim with?
The carrier that collected the charges. 49 CFR § 378.3 makes that carrier the one that processes the claim, and if you file with another carrier that took part in the movement, that carrier has 15 days to pass it on. The claim has to be in writing, and § 378.4 says it must come with the freight bill itself.
Can a carrier back-bill me months later?
Within limits, and the limits are tighter than the eighteen months people quote. 49 U.S.C. § 13710(a)(3)(A) says a carrier must issue any bill for charges in addition to those originally billed within 180 days of your receipt of the original bill in order to have the right to collect them. Separately, § 14705(a) gives a carrier 18 months from when a claim accrues to begin a civil action to recover charges. So a re-rating can still arrive long after a shipment you no longer remember, which is why the record that would let you argue with it has to be made on the day.
What is usually wrong on a freight bill?
In our experience, in order: the class, because the dimensions used to derive it were wrong; accessorial charges for services that were performed but never recorded, or not performed at all; and the weight. Duplicate payments and mis-billed payment terms are less common but larger when they happen, because nothing about them looks odd on the invoice.
Should I audit before or after paying?
Before, where your process allows it, because recovering money is slower than not sending it. Where volumes make that impractical, audit after payment on a sample and on every bill above a threshold, and treat any correction found as a reason to check the rest of that carrier's bills for the same pattern rather than as a one-off.
Is a freight bill audit worth it for a small shipper?
It depends on how many of your bills carry an accessorial or a re-rating, not on your volume. A company shipping twenty pallets a month with clean paperwork and one carrier may find nothing. A company whose deliveries frequently need a liftgate, or whose classes are derived from dimensions nobody re-measures, is likely paying corrections it could have prevented at the bay for nothing.

Sources

  1. 0149 U.S.C. § 14705: Limitation on actions by and against carriers · U.S. CodeSubsection (a): a carrier must begin a civil action to recover charges within 18 months after the claim accrues. Subsection (b): a person must begin a civil action to recover overcharges within 18 months. The clock runs both ways.
  2. 0249 U.S.C. § 13710: Concurrence and billing disputes · U.S. CodeThe shorter clock, and the practical one. Subsection (a)(3)(A): a carrier must issue any bill for charges in addition to those originally billed within 180 days of your receipt of the original bill to have the right to collect them. Subsection (a)(3)(B): a shipper must contest a bill within 180 days of receiving it to have the right to contest it. Subsection (a)(1) requires the carrier to supply the rate, classification, rules and practices on request.
  3. 0349 CFR Part 378: Processing, investigation and disposition of overcharge, duplicate payment or overcollection claims · Electronic Code of Federal RegulationsThe procedure almost nobody cites. § 378.3 requires a claim in writing to the carrier that collected the charges; § 378.4 says it must be accompanied by the freight bill; § 378.8 gives the carrier 60 days to pay, decline or settle, in writing, citing tariff authority if it declines.
  4. 0449 CFR § 373.101: Motor carrier bills of lading · Electronic Code of Federal RegulationsRequires the bill of lading to show weight, volume or measurement where it affects the rating. The document you are auditing against is the one you filled in.
  5. 05Decoding Density: The Freight Factor You Can't Afford to Overlook · National Motor Freight Traffic AssociationNames forgetting pallet or packaging height among the measuring errors NMFTA sees, which is the most common single cause of a re-rating landing on a freight bill.

This describes how the rules generally work in the United States and links to the primary sources so you can read them yourself. It is not legal advice, and your contract with a supplier or carrier can change any of it. For money that matters, ask a lawyer.

Four of the seven checks need a record made while the truck was still there. DockCount makes that record from a phone at the bay: the slip read and checked against the order line by line, with the photographs kept and dated. Free for 25 deliveries a month.