A container of bamboo boards is worth less per cubic metre than almost anything else in the terminal, and that is exactly why it is exposed. The freight is a large share of its value, the margin per unit is thin, and the charges that start accruing when paperwork slips are fixed per container per day rather than scaled to the value of the cargo. Buyers who model freight carefully and ignore free time are modelling the wrong half of the logistics cost. This piece explains how the clock actually runs at Santos, which delays are within your control, and how to build the sequence backwards from the vessel’s arrival.
Two clocks, not one
The word “demurrage” gets used loosely in Brazil to cover several different charges that run on different clocks and belong to different parties. It is worth separating them before you argue about any of them.
- Demurrage — the carrier’s charge for the container remaining inside the terminal beyond the free period counted from discharge. The carrier owns this clock.
- Detention — the carrier’s charge for the container remaining outside the terminal, in your custody, beyond the free period counted from gate-out. Also the carrier’s clock, but a different start point.
- Terminal storage — the terminal operator’s charge for cargo occupying yard space beyond its own free period. This is a separate contract with a separate tariff, and it can run at the same time as demurrage.
- Detention of the cargo itself — a customs or regulatory hold, which is not a charge but is the cause of all the others.
Because terminal storage and carrier demurrage run in parallel, a week of delay at Santos is not one charge, it is two, and the total is not visible on any single invoice. When a forwarder quotes you “demurrage”, ask which of the four they mean.
Free time is a contract term, not a fact
Every article about port charges quotes a number of free days. Treat all of them, including any you read here, as wrong for your shipment. Free time is set in the carrier’s tariff and in the service contract your forwarder or your importer holds, it differs by trade lane, by equipment type, by contract volume, and by whether the booking is a spot booking or a named-account booking. It is also negotiable — not container by container at the counter, but at the level of the annual service contract, which is where a buyer with predictable volume has real leverage and a buyer with two containers a year has almost none.
The practical instruction is simple: before the booking is confirmed, ask for the free time in writing for both demurrage and detention, and put both numbers in the shipment file. If the answer is verbal, it is not a term.
Where bamboo shipments actually lose the days
In our experience the losses are rarely caused by the vessel. They are caused by the sequence of the import file, and most of them are visible two weeks before arrival if anyone is looking.
| Cause | What happens | Who controls it | Prevention |
|---|---|---|---|
| Import licence or ANVISA clearance not started | The declaration cannot proceed; the container sits while the anuência is analysed | Importer / despachante | Lodge the licence as soon as the proforma is firm, not after the B/L is issued |
| NCM on the invoice differs from the NCM in the declaration | Customs questions the classification; the file is put under parameter review | Exporter and importer together | Agree the NCM in writing before shipment and print it on every invoice line |
| Packing list does not match carton marks | Physical verification is triggered; the container is held for inspection | Factory | Approve the packing list against the loading photos before the container leaves the factory |
| Wood packaging without correct ISPM 15 marking | The shipment is treated or refused; either way the clock runs | Factory | Photograph the pallet markings and keep them in the file |
| Importer registration or financial capacity issue | Clearance blocked at the system level, unrelated to the cargo | Importer | Test the registration with a small shipment before the seasonal build |
| Carrier rollover or terminal congestion | The vessel arrives late or the container is discharged in the wrong window | Carrier / terminal | Track the vessel, not the booking; re-plan the inland leg as soon as the ETA moves |
Four of those six are paperwork, and three of the four belong to the exporter’s side of the file. That is the argument for treating document quality as a supply-chain cost rather than an administrative chore. A factory that sends a clean invoice and a packing list that matches the cartons is worth more than a factory that is two percent cheaper and sends neither.
Build the timeline backwards from the ETA
The sequence that keeps a bamboo container out of the charge zone is not complicated, but it has to start early:
- Before booking: confirm NCM, confirm whether the product is food contact, and confirm the free time in the service contract.
- At booking: open the import licence process and the regulatory anuência, if applicable, using the proforma rather than the final invoice.
- Ten days before ETA: receive the draft B/L, the commercial invoice, the packing list, the certificate of origin and any test reports. Check them against each other, not against your memory.
- Five days before ETA: register the declaration so that it is ready when the cargo is “presence of cargo” confirmed.
- At discharge: book the inland leg and the empty return appointment at the same time. Returning the empty to the wrong depot restarts a different clock.
- At delivery: photograph the container interior before unloading. Bamboo claims are won and lost on what the inside of the box looked like at gate-out.
If your product needs a regulatory review that can take longer than the free time, the honest options are to pay for extended free time at booking, to route through a terminal with faster release, or to accept the charge as a line in the landed cost. The dishonest option, which is common, is to assume it will be fine. Our Brazil import guide for serving boards sets out the document file in the order the port expects it, and the quote form is where you can tell us the destination port so the packing and marks are prepared for that route.
The commercial argument for paying for free time
Extended free time has a price, and buyers resist it because it is visible on the quotation while the charge it prevents is not. The comparison is straightforward once you frame it as insurance: if the probability of a regulatory hold multiplied by the expected days of charge exceeds the cost of the extension, buy the extension. For a first shipment into a new market, with an unfamiliar NCM and an untested broker, that probability is not small.
There is a second, less obvious benefit. A buyer who has budgeted for the possibility of a hold negotiates from a different position than one who has not: the decision to pay for a faster release, or to accept a delay and re-plan the inland leg, is made with numbers rather than under pressure. That is worth something on its own.
Frequently asked
Who pays demurrage on an FOB shipment?
On FOB, CFR and CIF terms the consignee side carries the charges that arise after discharge, because the buyer controls the import clearance and the inland movement. On delivered terms the seller nominally carries them, but the cost is inside the price. Check which party the carrier has contracted with before assuming.
Is terminal storage the same as demurrage?
No. Terminal storage is charged by the terminal operator under its own tariff and its own free period; demurrage is charged by the carrier. Both can run at the same time on the same container, which is why the total is often larger than the number the forwarder quoted.
Can demurrage be waived?
Sometimes, when the delay is demonstrably caused by the carrier or the terminal, and when the request is made in writing with evidence before the charges are invoiced. Waivers are discretionary, not a right, and they are rarely granted for paperwork failures on the importer’s side.
Does a food-contact review extend the timeline for bamboo?
It can. Where a regulatory review applies, the container may be held while the file is analysed, and the hold period is not inside the carrier’s free time. Build that possibility into the shipping schedule for the first shipment of a new product into a new market.
Sources
- Agência Nacional de Transportes Aquaviários — ANTAQ
- Trade facilitation and port operations — World Trade Organization
- Logistics Performance Index — World Bank
Every figure above is traceable to these sources; where they disagree, both positions are stated. Values specific to our own products (carton size, 20GP loading, NCM, certificates) remain pending factory confirmation and are not presented as measured data. Regulatory summaries are a buyer’s working reference, not legal advice — confirm with your broker before you file.