Time to eliminate tariff, contract filing
The U.S. Federal Maritime Commission's decision regarding non-vessel-operating common carrier tariff filing is a good decision, one that reflects the practical way in which business is done. The decision helps everyone and hurts nobody.
The commission should now proceed to the next logical step: the elimination of tariff and contract filing for ocean carriers. This would eliminate a significant cost to the carriers, to our shipper, forwarder and NVO customers; and to the FMC; as well. It would eliminate useless data compilation, allowing the commission to focus more attention on proactively regulating ocean commerce.
Every one of our customers prefers the pricing simplicity of a cross-border move via Canada versus a move via a U.S. port ' all because of the filing issue. Ninety-eight percent of our U.S. port business is service contract versus less than half of U.S. cross-border cargo where there is no filing requirement. Our Canadian and U.S. cross-border tariff rates are lower than our U.S. port tariff rates because tariff rates and contracts are confidential and unfiled in Canada. So the filing requirement actually punishes smaller American shippers rather than help them.
American customers with service contracts always have changes to commodities or inland points than what was originally filed. If we do not get the information in time to file an amendment, the cargo must wait a week for the next sailing or pay a higher tariff rate ' all because of the filing requirement. So the filing requirement punishes the American shipper by forcing extra cost or shipment delays.
Without tariff and contract filing, the FMC could eliminate the expensive staffing and systems required to handle the huge filing volume and reallocate manpower to audits and investigations. The result would be more effective shippers, carriers, forwarders and NVOs, and an FMC that is even more focused on ensuring a level playing field and legal business behavior by all parties.
Andrew J. Abbott
president and chief executive officer,
Atlantic Container Line