Public Comments

Status: Original and derived artifacts are available for this document.

Download: pdf

VIA REGULATIONS.GOV — DOCKET FMC-2026-0067

March 26, 2026
Federal Maritime Commission
Office of the Secretary
800 North Capitol Street, NW
Washington, DC 20573
RE: Comments on Proposed Revision to OMB Control Number 3072-0074 —
Containerized Freight Statistics Collection

Introduction
Gnosis Freight submits these comments on the Commission’s proposed revision to
OMB Control Number 3072-0074, published January 26, 2026. The comment period
closes March 27, 2026.
Gnosis operates the AI Global Freight Operating System built on AI-native logistics data
infrastructure, providing real-time container-level visibility, execution, and data services
to commercial shippers, carriers, and logistics service providers. Our commercial clients
include Maersk, Hapag-Lloyd, GE Vernova, Continental Tire, and Rooms to Go. We are
an Automated Broker Interface (ABI) vendor with a direct electronic connection to CBP’s
Automated Commercial Environment for hold status and ISF data, and we maintain
active data connections with container shipping lines, container terminals, Class I rail
carriers, trucking networks, and AIS satellite providers across U.S. port operations. Our
Container Payment Portal is the first and only OSRA 2022-compliant demurrage and
detention management system in commercial operation, a development Gnosis
presented to the FMC’s National Shipper Advisory Committee in June 2025.
We’re not a carrier subject to these reporting requirements — we’re the company that
has built the logistics data infrastructure this collection is attempting to access, and we
operate it at commercial scale today.
The central argument across all five recommendations is the same: the commercial
logistics technology sector has already built the data infrastructure needed to validate
Comment on FMC Docket FMC-2026-0067 | OMB Control No. 3072-0074
Gnosis Companies, Inc. | 997 Morrison Drive, Suite 306 | Charleston, SC 29403

1

and expand the Commission’s containerized freight statistics. The FMC does not need
to construct new interagency arrangements, build internal verification systems, or
negotiate voluntary agreements with terminal operators. That work is done. What the
Commission needs to do is simple: add two fields to the 3072-0074 reporting schema,
and procure commercial data validation services from a provider with the connections
already in place.

I. The Validation Gap — and the Two Fields That Close It
The Commission’s current practice is to publish 3072-0074 data as “raw, self-reported
data with minimal processing” that the FMC “does not independently validate or verify.”
For a dataset that now informs quarterly public reporting under 46 U.S.C. § 41110, that
is a structural problem — and the Commission’s own MTDS report documented that
some carriers are “not willing to fully embrace the need to provide public information.”
The current framework gives the FMC no way to check.
The fix requires two additional mandatory fields in the 3072-0074 submission schema:
master bill of lading (MBL) numbers and container numbers. That is the only change to
the collection itself that the Commission needs to make.
With those identifiers, a commercial validation provider can query ocean carrier
systems, terminal operators, and — for containers with inland rail transit — rail carriers,
cross-checking each reported container against actual event records. This capability
exists and operates at commercial scale today. It does not require the FMC to build new
infrastructure, establish new technology relationships, or issue new guidance to terminal
operators.
Container type and weight data — available from carrier data feeds for each container
number — provides an additional validation layer for the TEU counts and tonnage
figures at the core of the 3072-0074 collection. Where a carrier’s aggregate reported
tonnage diverges from the sum of individual container weights on file, or where reported
TEU counts don’t match the container type breakdown in carrier records, those
discrepancies surface through the same query process. This moves the collection from
self-reported totals to figures that can be verified at the individual container level.
For completeness verification — detecting whether a carrier omitted MBLs from its
submission — CBP vessel manifests provide the independent baseline. Every container
that legally enters a U.S. port must appear on a vessel manifest filed with CBP, and
those manifests become publicly available within days of vessel arrival. Crossreferencing a carrier’s FMC submission against the manifest for the same vessel calls
surfaces omissions directly. Where shippers have requested confidential treatment
Comment on FMC Docket FMC-2026-0067 | OMB Control No. 3072-0074
Gnosis Companies, Inc. | 997 Morrison Drive, Suite 306 | Charleston, SC 29403

2

under 19 C.F.R. § 103.31, shipper and consignee identity is suppressed, but container
numbers remain part of the public record — the completeness check is not affected.
The few-day lag in manifest availability is well within the Commission’s monthly
reporting and quarterly publication cycle.
The Commission does not need a formal interagency arrangement with CBP to access
this data. It is publicly available. A commercial validation provider with ABI vendor status
can access hold status through an existing direct CBP connection, and manifest data
through standard public channels. No new government-to-government agreements are
required.
Recommendation: Add master bill of lading numbers and container numbers as
mandatory fields in the 3072-0074 reporting schema. Procure commercial data
validation services from a provider with existing carrier API integrations, terminal
query capability, and ABI vendor status. The validation infrastructure does not need
to be built — it exists today.

II. Event-Based Reporting — Enabled by the Same Identifiers
The current collection captures TEU counts and tonnage per vessel at port level — a
volume snapshot that tells the Commission what arrived, not what happened to it. The
MTDS recommendations identified harmonized container status (Available, Unavailable,
On Hold, Cargo Handling) and real-time ETA data as priorities. These require eventbased reporting, not aggregate counts.
The MBL and container number fields recommended in Section I are the prerequisite.
Once those identifiers are in the submission schema, the same commercial provider
performing accuracy validation can query carrier, terminal, and rail carrier systems for
each container’s actual milestone history: port discharge, gate-out, availability
confirmation, inland transfer. The FMC gets event-level data without adding burden to
its own infrastructure. The query capability — reaching carriers, terminals, and rail
operators — already exists in commercial systems serving major U.S. importers today.
A vessel arriving with 2,400 TEUs is materially different from one arriving with 2,400
TEUs of which 600 are under CBP hold — the current collection captures neither the
distinction nor its economic significance. Event-based reporting, built on container-level
identifiers, closes that gap.
Recommendation: Expand the reporting schema to include container-level status
events at port discharge, gate-out, and availability confirmation, aligned with the
MTDS harmonized container status taxonomy. Phase implementation starting with

Comment on FMC Docket FMC-2026-0067 | OMB Control No. 3072-0074
Gnosis Companies, Inc. | 997 Morrison Drive, Suite 306 | Charleston, SC 29403

3

the highest-value events. The MBL and container number fields from Section I are
the enabling prerequisite.

III. Inland Visibility
Current collection scope ends at the marine terminal gate. For containers moving by rail
to inland destinations — a significant share of import volume at major load centers —
the Commission has no visibility past the port.
The query capability described in Section II extends to rail carriers for containers with
inland transit. With container numbers as the linking identifier, a commercial validation
provider can track milestone events through the rail leg and report on inland delivery
status. This doesn’t require the Commission to expand its statutory scope or build new
data relationships. It follows directly from having container numbers in the submission
schema.
Recommendation: Require that any commercial validation contract include active
Class I rail carrier data connections, extending the Commission’s visibility past the
port gate without additional collection burden on carriers. Container number
submission is the enabling identifier; the rail carrier query capability does the rest.

IV. Enhanced Verification for Controlled Carriers
The Commission and Congress are both revisiting the regulatory framework for stateowned or state-influenced carriers. The FMC Reauthorization Act, which passed the
House in December 2025 and is pending in the Senate, expands the controlled carrier
definition and adds oversight of the Shanghai Shipping Exchange. The direction is clear:
data from carriers with government ownership or influence warrants independent
verification, not just self-reporting. A sovereign data model means U.S. import and
export freight data is verified through U.S.-operated infrastructure, independent of
foreign carrier self-reporting. The revised 3072-0074 collection, paired with commercial
validation services, would establish that model.
Under the current 3072-0074 framework, carriers meeting the controlled carrier
definition submit data under the same standard as private carriers. The MBL crossreference mechanism described in Section I is particularly significant here. For a stateowned enterprise, comparing FMC-submitted figures against CBP vessel manifest data
provides an independent check that does not rely on the carrier’s own reporting. If a
controlled carrier’s submission diverges from its manifest, that discrepancy surfaces
Comment on FMC Docket FMC-2026-0067 | OMB Control No. 3072-0074
Gnosis Companies, Inc. | 997 Morrison Drive, Suite 306 | Charleston, SC 29403

4

through the same commercial validation process — no additional FMC infrastructure
required.
For carriers meeting or likely to meet the expanded controlled carrier definition, the
Commission should require a formal attestation from a named corporate officer
certifying the submission’s accuracy and completeness — the same accountability
structure used in federal financial reporting. The named officer carries personal legal
exposure if that certification is knowingly false. Combined with commercial crossvalidation, this creates a documented chain: the officer has certified the data is
accurate, and an independent system has either confirmed or contradicted it. When
those two don’t align, the Commission has both a signed certification and independent
evidence of inaccuracy — a far cleaner predicate for enforcement action than a data
discrepancy alone. For state-owned enterprises in particular, requiring a named
individual at a government-affiliated carrier to personally certify accuracy to a U.S.
regulatory agency is a meaningful structural change from the current framework.
Recommendation: Establish tiered verification requirements keyed to carrier
classification. For carriers meeting the controlled carrier definition, require corporate
officer attestation and mandate cross-validation against CBP manifest data prior to
incorporation in public quarterly reports. The commercial validation infrastructure
described in Section I supports this without additional FMC build.

V. What the FMC Should Do
The four recommendations above share a common implementation path. The
Commission does not need to build new data collection infrastructure, pursue new
interagency arrangements, or negotiate voluntary agreements with terminal operators or
rail carriers. The commercial logistics data infrastructure that supports all four
recommendations already exists, is already connected to the relevant carrier, terminal,
and government data sources, and is already operating at scale.
What the Commission needs is two things. First, revise the 3072-0074 reporting
schema to add MBL numbers and container numbers as required fields. This is a
regulatory change to a data collection form — it does not require new statutory
authority. Second, issue a data services contract to a commercial provider with ABI
vendor status, active data connections with ocean carriers, terminals, and rail carriers
serving U.S. ports. That provider must be able to deliver 95% or greater accuracy and
completeness across carrier, terminal, and rail carrier records for each submitted
container, and through CBP public manifest cross-reference.

Comment on FMC Docket FMC-2026-0067 | OMB Control No. 3072-0074
Gnosis Companies, Inc. | 997 Morrison Drive, Suite 306 | Charleston, SC 29403

5

Any solicitation for data validation services should specify a technical requirement that’s
easy to overlook: source data normalization. Container shipping lines, terminal
operators, rail carriers, CBP, and AIS satellite providers each use different data formats,
identifier schemas, and event taxonomies — a provider that can’t normalize across
those sources will produce false discrepancies from format differences rather than
genuine data quality issues. The provider specification should require active data
connections across all relevant source types, a translation layer that maps sourcespecific identifiers to a common container reference standard, and an AI-native
architecture capable of resolving conflicts between source records in real time. Data
completeness and data accuracy both depend on this underlying data model. These
capabilities are what separate a purpose-built logistics data infrastructure from a data
aggregation service.
On carrier participation incentives: the Commission should consider a safe harbor
provision for carriers who submit data that passes validation — for example, a
streamlined review process in enforcement proceedings for carriers with a documented
record of accurate, validated submissions. Positive incentives for accurate reporting
complement the compliance mandate and are likely to produce better data quality
outcomes than mandate alone.
The MTDS recommendations, OSRA 2022, and the FMC Reauthorization Act together
create a clear legislative mandate for improved data quality. The AI-native logistics data
infrastructure needed to deliver on that mandate exists today, operating at commercial
scale. The procurement path is a data services contract, not an infrastructure program.
Recommendation: Issue a data services contract to a commercial logistics data
provider with the carrier, terminal, and government data connections described
above. Pair with the schema changes in Sections I and II. The Commission’s
implementation burden is limited to those two actions.

Conclusion
The proposed revision to 3072-0074 does not require the Commission to build new data
infrastructure or establish new interagency relationships. The commercial logistics
technology sector has already built what is needed. The FMC adds two fields to the
reporting schema and issues a data services contract to a provider with the connections
already in place. The Commission gets validated, event-level, container-specific data —
including completeness verification and controlled carrier cross-checks — without
constructing anything new.

Comment on FMC Docket FMC-2026-0067 | OMB Control No. 3072-0074
Gnosis Companies, Inc. | 997 Morrison Drive, Suite 306 | Charleston, SC 29403

6

Gnosis Freight is prepared to brief Commission staff on our validation architecture,
integration approach, and milestone taxonomy in connection with the revised collection
design and any related procurement planning.
Respectfully submitted,
Adam Baker
Vice President
Gnosis Companies, Inc. (Gnosis Freight)
[email protected]
253-905-3933

Comment on FMC Docket FMC-2026-0067 | OMB Control No. 3072-0074
Gnosis Companies, Inc. | 997 Morrison Drive, Suite 306 | Charleston, SC 29403

7