In a year marked by digital acceleration and supply chain reinvention, one stubborn issue continues to undermine progress in ocean freight: vessel schedule reliability. According to Sea-Intelligence’s Global Liner Performance report, global schedule reliability across 34 major trade lanes averaged just 64.7% in 2025, with average delays of five days per vessel arrival. While this reflects modest improvement from pandemic-era lows—such as 30.4% in early 2022—it remains well below pre-COVID benchmarks of 75–80%, and far from acceptable for shippers managing time-sensitive cargo and complex intermodal transitions.
This persistent unreliability is not just a nuisance—it’s a structural flaw. It disrupts inventory planning, inflates buffer stock requirements, and erodes trust in carrier commitments. The root cause is not a lack of visibility tools or tracking platforms, but the absence of clear, consistent, and enforceable data standards between carriers and shippers. Until this foundational gap is addressed, the promise of digital transformation in freight management will remain unfulfilled.
Drawing from collaborative efforts between American Cotton Shippers Association (ACSA) and the National Shipper Advisory Committee (NSAC) with the Federal Maritime Commission (FMC), this article explores why foundational data standards must be treated as infrastructure—just as vital as vessels, ports, and terminals. It also argues that access to essential shipment data is not merely a best practice, but a contractual right embedded in the carriage of goods.
The aligned objectives and synergy between policy influencers, the regulatory community, and private sector stakeholders would not exist or be so carefully delivered without the leadership of industry trade associations whose objectives are delivered with consensus through the conduit of NSAC. Recognizing the changing leadership at the FMC, industry stakeholders should continue engaging with the FMC and support the development of a parallel advisory board comprised of ocean carriers to establish an organized and ethical forum for collaboration and progress.
The Problem: Fragmented Data in a Connected World
Despite the proliferation of Transportation Management Systems (TMS), digital freight platforms, and real-time tracking tools, shippers and ocean carriers still struggle to communicate basic shipment data consistently and reliably. Freight rates, container milestones, vessel schedules, and intermodal transitions are often recorded in disparate formats, updated inconsistently, and shared through siloed systems.
This fragmentation leads to:
- Unpredictable export shipping windows due to shifting vessel schedules
- Delayed cargo release from mismatched data.
- Disputed charges from unclear demurrage and detention records.
- Inefficient planning and forecasting.
- Eroded trust between stakeholders.
The result is a system where visibility is promised but rarely delivered.
NSAC’s Three Pillars of Data Reform
In December 2022, NSAC submitted a landmark set of recommendations to the FMC focused on aligning data across three critical levels: Vessel, Container, and Intermodal. These recommendations were designed to establish a shared language and structure for data exchange, enabling transparency and accountability across the supply chain.
- Vessel-Level Data Alignment
NSAC proposed that all ocean carriers align vessel-level data for each vessel call. This includes:
- Estimated and actual arrival/departure times,
- Port of loading and destination,
- Vessel berthing and discharge dates,
- Transshipment milestones,
- IMO-defined vessel names.
Standardizing these elements enables better cargo flow forecasting and reduces uncertainty for downstream operations.
- Container-Level Data Transparency
The second recommendation urged carriers to publish key container milestones with historical timestamps in a public format accessible for up to two years. These include:
- Terminal ingate and departure dates,
- Discharge and pickup availability,
- Last free day and detention deadlines,
- Customs holds and outgate details.
This empowers shippers to track containers with precision, resolve disputes faster, and optimize drayage and warehouse planning.
- Intermodal Data Accessibility
NSAC also called for intermodal data—especially for containers moving on U.S. railways under through bills of lading—to be made publicly accessible. This includes:
- Estimated and actual train arrival/departure,
- Real-time container status at destination,
- Last free dates for yard and equipment detention.
This recognizes that ocean freight doesn’t end at the port. Intermodal transitions are critical choke points, and without aligned data, they become blind spots.
FMC’s Aligned Actions and Direction:
Fact Finding 29: Data as a Contractual Right
The FMC’s Fact Finding 29 Final Report reinforced NSAC’s recommendations and went further: it asserted that access to essential shipment data is a right within the contract of carriage. The report emphasized that mutually enforceable service contracts must include agreed-upon data elements to ensure operational clarity and protect both parties from volatility.
Key findings from Fact Finding 29 include:
- Demurrage and detention charges must be based on transparent, timely data and serve the purpose of incentivizing cargo movement—not penalizing shippers for systemic failures.
- Earliest Return Dates (ERDs) and empty container return practices must be communicated clearly and consistently to avoid unnecessary fees and disruptions.
- Blank sailings and terminal closures must be announced with sufficient lead time to allow shippers and truckers to adjust operations.
The FMC concluded that without enforceable contracts and standardized data, shippers are left vulnerable to unpredictable costs and carriers lack the forecasting tools to serve their customers effectively.
Marine Transportation Data Initiative (MTDI) – Further Aligning Objectives
FMC’s MTDI final report came to a similar assessment after robust industry engagement and called for deeper integration of data across the maritime and intermodal ecosystem. These include:
- Schedule Reliability: Mandating real-time updates for schedule changes, blank sailings, and ETAs via standardized APIs.
- In-Transit Visibility: Promoting IoT-enabled devices and blockchain for secure, interoperable data exchange.
- Detention and Demurrage Transparency: Establishing centralized platforms for tracking charges with real-time updates and dispute resolution mechanisms.
- Port Operations Coordination: Creating digital repositories for port-wide operational data and using AI to identify bottlenecks.
- Earliest Receiving Date (ERD) Notification: Requiring real-time publication of ERDs and predictive analytics to proactively identify disruptions.
These priorities reflect a growing consensus: data is not optional —it’s operational.
The Path Forward: Regulation, Collaboration, and Accountability
The FMC has responded with a series of rulemakings and initiatives to bring coherence and clarity to data practices:
- Rulemakings on empty container return and ERD practices to ensure timely and reliable communication.
- A new International Ocean Shipping Supply Chain Program to study and address systemic challenges.
- Enhanced interagency cooperation with USDA and DOT to support agricultural exporters and intermodal coordination.
- A revived Rapid Response Team to resolve urgent commercial disputes with carrier CEO-level engagement.
These efforts signal a shift from voluntary data sharing to regulated data accountability.
Conclusion: Data Is Infrastructure—and a Right
In ocean freight, data is not just a byproduct—it is infrastructure. Without foundational standards, even the most advanced technologies will fail to deliver on their promise. The NSAC recommendations and FMC’s Fact Finding 29 offer a blueprint for change, but it will take collective will to implement them.
More importantly, access to essential shipment data is not a privilege—it is a right embedded in the contract of carriage. Shippers and carriers must move beyond vague rate agreements and embrace mutually enforceable contracts that include clear data obligations.
As we move toward a more agile, transparent, and resilient supply chain, let us start with the basics: clear, concise, and consistent data. It’s the missing link—and the foundation—upon which the future of resilient, transparent, and equitable ocean freight must be built.
References
- NSAC Data One Pager, December 2022
- FMC Fact Finding 29 Final Report, 2023
- MTDI Final Report, January 2025
