Billing SIT in 30 & 90 Day Increments
The billing of storage charges usually occurs when the shipment is delivered out of SIT. However, in this time of the stop movement order, collecting all available cash as soon as possible becomes even more important. Daycos has been researching options to be able to bill storage charges sooner than delivery out. There is guidance in the 400NG, which allows SIT billing in 90-day increments of storage. However, after research of DTR language and consultation with USTC, Daycos has determined that destination SIT can be billed in 30-day increments, opening up a potential way to improve cash flow
Conflicting Language
The ability to bill SIT charges in 90-day increments is specified in Item 17 of the 400NG. (The International Tender makes no mention of SIT billing increments.) However, in research Daycos has done on the DTR, we found language that supports 30-day increment billing for destination SIT:
Resolving the Conflict
In general, when there is a conflict between the DTR and the tariffs, we follow the DTR regulations. However, we reached out to USTC to get their interpretation as well, and they instructed us that for destination SIT, billing in 30-day increments was allowed. However, since there was no language in the DTR for origin SIT, that would still need to be billed in 90-day increments.
International Impact
Since the International Tender does not address SIT Billing increments, the DTR language of 30 days applies for Destination SIT. However, for Origin SIT, it would appear that storage may not be billed until shipment is delivered out.
Summary
Here is the current Daycos billing guidance on billing SIT charges before shipment delivers out:
- Domestic Shipments
- Origin SIT: Can be billed in 90-day increments
- Destination SIT: Can be billed in 30-day increments
- International Shipments
- Origin SIT: Cannot be billed before delivery out
- Destination SIT: can be billed in 30-day increments
Next Steps
If you have shipments in destination SIT longer than 30 days, or origin SIT longer than 90 days for domestic shipments, then Daycos will bill those storage charges at the appropriate intervals if you register them on a supplemental invoice. Each customer will have to decide if that makes sense for them and their billing processes, but at least the option is available now.
If you need assistance identifying eligible shipments, contact us at support@daycos.com,and we may be able to assist you with reports that would identify shipments eligible for SIT storage increment billing.
