Field Notes measured from China

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2026-10-11·11 min read

Choosing a freight forwarder: reading the quote

A forwarder quote is a stack of other people's rate cards: which lines are published, which are private price, and how to check the two credentials.

Living page — numbers read from the sources on 2026-10-11, re-checked quarterly.

A forwarder’s quotation is a stack of other people’s rate cards. A few are published by law. Some are set by a terminal. Some are the forwarder’s own labour, priced by nobody else. Two quotes can sit far apart and both be honest, because the two sellers are not selling the same thing.

This page does not name forwarders or rank them. It sets out what each charge is, who owns it, why an all-in number resists comparison, and how to check whether the company quoting you may do the work. The ocean leg is in Container rates by route; who carries each task is in Incoterms in one page. This one is about the invoice.

The lines on a quote, and who owns each one

Origin and the ocean leg. All rates were read on 11 October 2026.

LineWho sets the amountPublic cardWho paysNote
Ocean freight, booking includedthe carrier, in its own tariff or a negotiated rateyes, and free to read (46 CFR 520.9(c)(2); FMC advisory, 4 January 2024)buyer under FOB; seller under CFR/CIFan index reading is not a quote; see the container-rates page
Origin terminal handling (港口作业包干费)the terminal operator; a market price in Chinayes, on the operator’s own published cardwhoever the term puts at the portthe charging rules list what must be bundled inside it (港口收费计费办法, art. 36)
Cargo port dues (货物港务费)government-setyes, in the ministry’s rate tablethe cargo side, or its agent¥17 per 20ft and ¥34 per 40ft outbound; ¥34 and ¥68 inbound, on general-cargo boxes (rate table, 交水规〔2019〕2号, effective 1 April 2019)
Port facility security fee (港口设施保安费)no longer a government price; it sits inside the terminal’s lump-sum handling fee as a sub-item, capped at the old ratethe cap is in the same rate tablethe cargo side, or its agent¥8 per 20ft and ¥12 per 40ft on laden boxes is the cap; its government price was cancelled on 1 April 2022 (交水发〔2022〕26号)
Export declaration (报关)a customs broker; market priceno fee card foundseller under FCA/FOB, buyer under EXWa broker must file with customs, which replaced the licence in 2022 (报关单位备案管理规定, 海关总署令第253号, effective 1 January 2022, read 11 October 2026)
Trucking to the porta trucker, market pricenone foundfollows the termwaiting time and liftgate usually sit outside the line
Low-sulphur surcharge (LSS)the carrier, per its own noticeno single cardfollows the freightthe rule behind it is the IMO sulphur cap: 0.50% from 1 January 2020, 0.10% inside emission control areas (IMO, 20 December 2019)
Documentation, B/L, AMS, ISF entriesforwarder or carrier, market pricenot on the customs fee tablefollows the termCBP’s own table carries arrival fees, MPF and HMF, and no AMS or ISF line (CBP user fee table, page updated 9 October 2026, read 11 October 2026)

Destination side. This is where two quotes diverge most, and where the published cards stop helping you.

LineWho sets the amountPublic cardWho paysNote
Destination terminal handlingthe destination terminalonly if the operator chooses to publish one (46 CFR 525.2(a))the buyer, under FOB and CIF alikea published schedule must be reachable online, and a reasonable access charge is allowed (46 CFR 525.3)
Import clearance broker feea broker, market pricenonethe buyer, except under DDPa minimum fee is normal on small shipments
Merchandise Processing FeeCBPyesthe importer of record0.3464% of value, minimum $34.58, maximum $670.86, plus $4.15 for a manual entry, required from 1 October 2026 (Federal Register, 31 July 2026; CBP user fee table, read 11 October 2026)
Harbor Maintenance Feestatute, collected by CBPyesthe importer of record0.125% of value (CBP user fee table, citing Public Law 99-662, read 11 October 2026)
Duty and trade measurescustoms, per the tariff scheduleyesbuyer, or seller under DDPthe one line a forwarder cannot negotiate
Demurrage: the box sitting in the terminalthe terminalyes, in its schedulewhoever the schedule may invoicesee the trap below: free time can exclude weekends
Detention: the box out of the terminalthe carrier or the NVOCCyessamea US invoice must issue within 30 days of the charge (46 CFR 541.7)
Storage, once it leaves the wharfthe terminal, market priceyesthe buyerin China this is 库场使用费, priced by the operator (港口收费计费办法, art. 39–40)

Why an all-in price cannot be compared

Bundling is a choice, and in China it is a constrained one. Of the two port charges that used to be government prices, one still is. The security fee stopped being one on 1 April 2022, when the ministry and the NDRC folded it into the terminal’s lump-sum handling fee as a sub-item, capped at the old rate (交水发〔2022〕26号).

Two rules survive. An agent collecting the government-priced cargo dues on the owner’s behalf may not add a margin (same notice, part four). And the terminal’s lump-sum handling fee may not contain the government-priced items or other market-priced items, which are billed as separate lines (港口收费计费办法, art. 38, extended in 2024). A Chinese port invoice that cannot be broken down is a packaging choice, and the regulation gives you two lines to point at.

Three other reasons a single number resists comparison:

The endpoints differ. “All in” can mean to the port, to a rail ramp, or to your door. Three products, three prices, and the difference sits in a trucking market the quote never shows.

The risk boundary differs. Under CIF the seller arranges and pays carriage to the destination port while risk passes once the goods are on board at the shipment port (ICC Academy, 7 October 2024). Under DDP the seller carries import clearance and duty, and freight, duty and clearance collapse into one figure (ICC Academy). A DDP figure and an FOB figure cannot be compared line by line.

The clock differs. A quote with no validity date carries an unstated currency position. The renminbi appreciated 4.07% against the dollar between 7 January and 9 October 2026 on the PBOC central parity, 7.0187 to 6.7330 (7 January, 9 October).

Putting two quotes on one ruler

Eight questions, asked in writing, turn two quotes into a comparison.

  1. Which Incoterm, and at which named place? FOB at one port and FOB at another are two products.
  2. Which box type, and where does the carriage end? CY to CY, port to door, and door to door price differently.
  3. What is the chargeable basis? Weight or measure for LCL, per container for FCL, chargeable weight with the volume divisor stated for air.
  4. How many free days, and which days count? Ask for demurrage free time and detention free time separately, and whether weekends and closed holidays are excluded. In the terminal schedule below they are.
  5. Which lines are pass-through at cost, with the third party’s invoice attached? In China the cargo port dues are the clearest case, because the regulation forbids a margin on them.
  6. Which currency, converted at which date, and how long is the quote good for?
  7. Which lines are optional? Cargo insurance, a customs bond, an ISF filing, chassis, liftgate, waiting time, and any per-diem after free time.
  8. Which tariff rule does the ocean rate come from? Carriers must publish a tariff (46 CFR 520.3), and common carriers and conferences must give free public access to the publication system, in force since 1 February 2024 (FMC advisory, 4 January 2024). Ask for the rule number.

The two credentials, and how to check them

In China, a freight forwarder files with the commerce ministry. The instrument is the 2005 filing measures, 商务部令2005年第9号, effective 1 April 2005, amended in 2016 (text, gov.cn, read 11 October 2026). MOFCOM’s service description still lists that order as the legal basis, says the matter carries no fee, and puts the filing inside the 国际货运代理企业信息管理系统; the work runs through provincial commerce departments and, under 商服贸发〔2013〕11号, the national forwarders’ association (MOFCOM service description, read 11 October 2026). Results are queryable on the ministry’s disclosure platform, by name, place of business and service items (query page, read 11 October 2026). I read that list, not the filings behind it.

In China, an NVOCC files with the transport department. An NVOCC issues its own bill of lading and takes carrier liability, which the 国际海运条例实施细则 defines at article 3(4) (实施细则, 交通运输部令2023年第16号, fifth amendment, 10 November 2023). Its licence was cancelled by the State Council in 2019, so the requirement now is a filing: within 15 days of starting business, the company gives registration details to the provincial transport department where it is registered, or where business mainly happens (交办水函〔2019〕681号, 14 May 2019; 实施细则 art. 9). That notice left the freight-rate filing requirement unchanged. Provincial transport departments publish lists of filed operators; the latest I could read was dated 31 January 2025 (list page, read 11 October 2026). Ask for the filing receipt and the province.

In the United States, the check is the FMC. The Commission licenses ocean transportation intermediaries and requires proof of financial responsibility. Its public OTI list states what a listing means: a licensed forwarder has a licence and financial responsibility on file; a licensed NVOCC additionally has a current Form FMC-1 tariff filing; a foreign-based NVOCC has filed Form FMC-65 and a tariff (FMC OTI list, read 11 October 2026). The page carries the exclusion that matters: an NVOCC without an active Form FMC-1 is not on the list. It also publishes a weekly list of NVOCCs licensed or registered but with no tariff, contrary to 46 CFR 520.3, warned of a licence at risk (FMC, Non-Compliant NVOCCs, updated Fridays, read 11 October 2026). Check both lists, then read the tariff.

A licence says the company may act and has posted security, and nothing about service quality.

Four traps

Free time is not calendar time. One terminal’s published schedule allows four free days on inbound foreign-trade containers, exclusive of Saturdays, Sundays and the holidays on which the terminal is closed (TTI terminal schedule, Port of Long Beach, file posted July 2026, read 11 October 2026). The same page says a Saturday or Sunday counts if the terminal announces its gates are open. Four free days can burn through a weekend. Ask for the last free day as a date, not as a number.

Demurrage escalates in bands. The same schedule charges a box with an overall length of 21 to 40 feet $64.58 a day for the first five days, $128.13 a day for days six to ten, and $255.23 a day after that, with weekends and holidays included once free time has expired. A separate congestion fee of $100 a day for days 9 to 14 and $150 a day after sits on top of demurrage, in force since 10 January 2022.

Demurrage and detention have a rulebook worth quoting, and it just got shorter. The FMC’s billing rule requires an invoice within 30 days of the date the charge was last incurred, requires the bill of lading and container numbers on it, and provides that omitting required information removes the obligation to pay (46 CFR 541.5 to 541.7, 89 FR 14362, 26 February 2024, effective 28 May 2024). One section is gone: 46 CFR 541.4 limited who could be billed, the D.C. Circuit severed it in September 2025, and the Commission removed it effective 29 December 2025 (FMC final rule; World Shipping Council v. FMC, 152 F.4th 215 (D.C. Cir. 2025)). The rest of the rule stands. “You billed the wrong party” is a weaker argument than it was in 2024.

A documentation fee is a commercial price. AMS and ISF entries, B/L fees and file-handling charges are set by whoever bills them. If a pass-through is claimed, ask for the invoice behind it.

How this page was put together

Every figure was fetched or re-read on 11 October 2026. The Chinese rate figures come from the rate tables attached to the ministry’s 2019 charging rules, whose five-year term expired and was extended by a 2024 announcement (交水规〔2024〕4号, 6 April 2024); the security fee’s changed status comes from a 2022 notice, to which the 2024 announcement routes that item. The US figures come from the Federal Register notice setting FY2027 user fees, cross-read against CBP’s own fee table, which the agency warns may lag the notices. The demurrage numbers come from one terminal’s published schedule, named as an example, not as a recommendation. The FMC and eCFR rules are quoted from the current text, and one section was re-checked after I found it missing from the current CFR.

For the demand side, Google’s autocomplete was queried the same day. Completions for “china freight forwarder” run to “to usa”, “reddit”, “to india”, “to uk”, “to canada”, “to singapore” and “to nigeria”; strings starting “best china freight forwarder” and “cheapest china freight forwarder” return route names with “reddit” recurring. People search for a per-route name and for someone else’s experience. Neither answers whether the company may file the paperwork.

What I could not check

  • Whether the 2005 filing measures are still formally in force. MOFCOM still lists 商务部令2005年第9号 as the legal basis, and no repeal appeared. That is a reading of current pages, not a gazette search.
  • The filing records themselves. The public query returns names, places of business and service items. I did not open the filings behind any row.
  • China declaration and trucking rates. No fee card found. The customs filing duty is published; the price of the work is not.
  • Whether the national single window charges for a declaration. Not verified.
  • Current low-sulphur surcharge rates. The IMO rule is published; the amount is set carrier by carrier. I collected no LSS card, so treat that line as unverified.
  • A national picture of NVOCC filing lists. I read one provincial-level list, latest edition 31 January 2025. Other provinces publish in other formats and cycles.
  • Whether any specific terminal’s demurrage numbers are typical. I have one schedule, at one port. The bands and the escalation are the pattern to expect; the dollars are that terminal’s.
  • The FMC’s licence-status change lists. I read the landing pages and the non-compliant list, and did not page through the status-change records.