Deadline Announced for Required Filing of Annual Export Strategies at FMC

Ocean common carriers must file documented export strategies with the Federal Maritime Commission beginning March 1, 2025, and at least annually every following year. The deadline for the first submission is December 31, 2024.

These filings are crucial as they must include comprehensive information on services offered, markets served, pricing strategies, and equipment provisioning. The submissions must be prospective in nature, providing clear information to the Commission about how ocean carriers will serve the U.S. export market. Multiple filings in a year are permitted if circumstances warrant.

The requirement to file a documented export strategy was established by the final rule “Definition of Unreasonable Refusal to Deal or Negotiate with Respect to Vessel Space Accommodations Provided by an Ocean Common Carrier,” which was published in July. This rule was mandated by the Ocean Shipping Reform Act of 2022.

Although the final rule has been in effect for almost five months, approval for the Commission to collect export strategy filings was required from the Office of the Management and Budget. This approval was provided earlier this fall, clearing the way for establishing the December 31, 2024 reporting deadline.

It is essential for ocean common carriers to adhere to this deadline and ensure they submit their documented export strategies to the Federal Maritime Commission in a timely manner. Failure to comply with this requirement may result in penalties or other regulatory actions.

Overall, this new regulation aims to enhance transparency and accountability within the maritime industry, ensuring that ocean carriers are proactively planning and outlining their strategies for serving the U.S. export market. By providing detailed information to the Commission, carriers can demonstrate their commitment to meeting the needs of exporters and supporting the growth of the U.S. economy through efficient and reliable shipping services.