Tariff Filing Requirements: What Interstate Movers Must Know

If you hold FMCSA authority to transport household goods interstate, you're required to maintain a tariff. Full stop. There's no exception for small companies, no exemption for movers who only do a few interstate jobs per year, and no grace period for new entrants. Your tariff must be in place before you accept your first interstate shipment.

Despite this, tariff compliance is one of the most frequently violated regulations in the household goods moving industry. FMCSA compliance reviews routinely flag tariff issues, and complaints from consumers about undisclosed charges often trace back to tariff problems. Here's what you need to know.

What Exactly Is a Tariff?

A tariff is a publicly available document that lists all the rates, rules, and charges you apply to interstate household goods shipments. Think of it as your official price list — not what you charge on any individual job (that's the estimate), but the underlying rate structure from which estimates are derived.

Before 1995, household goods movers were required to file tariffs with the Interstate Commerce Commission and could only charge the filed rates. The deregulation under the ICC Termination Act of 1995 changed this — movers are no longer required to file tariffs with a government agency, but they are still required to maintain tariffs and make them available to customers upon request.

Under 49 CFR 375.103 and 375.501, your tariff must be available for public inspection, and you must make it available to any shipper who requests it. In practice, this means keeping it at your place of business and ideally accessible on your website.

What Must the Tariff Include?

Your tariff needs to be comprehensive enough to support every charge that appears on a customer's bill. If you charge for it, it must be in the tariff. Specifically:

Transportation rates:

• Linehaul rates (per hundredweight by distance, or per-mile rates for truckload shipments)
• Minimum charges
• Rates for specific shipment weight ranges

Accessorial charges:

• Packing and unpacking (per carton, per item category, or hourly rates)
• Crating and uncrating for specialty items
• Long carry (beyond a specified distance from truck to residence)
• Stair carry (per flight)
• Elevator carry
• Shuttle service (when a standard moving van can't access the residence)
• Appliance servicing (disconnect/reconnect washers, dryers, etc.)
• Bulky article handling (hot tubs, safes, pool tables, pianos)
• Storage-in-transit rates (warehouse handling, monthly storage per vault)
• Waiting time or delay charges

Valuation charges:

• Released value (60 cents per pound per article — included at no additional charge)
• Full value protection options and premium rates

Rules and regulations:

• Credit and payment terms
• Pickup and delivery windows
• Claims filing procedures
• Cancellation policies
• Terms governing SIT conversion to permanent storage

If your tariff is missing an accessorial charge that you later bill a customer for, you have no legal basis to collect it. Worse, it can trigger a complaint with FMCSA and put your authority at risk.

How Do You Create and Maintain a Tariff?

You have two options:

Option 1: Publish your own tariff. You create a document that lists all your rates and rules. This gives you complete control over your pricing structure and can be updated at any time. The document should be professionally formatted, dated, and include an effective date for each rate change.

Option 2: Participate in a collective tariff. Organizations like the American Moving and Storage Association (AMSA) have historically published collective tariffs that multiple carriers can adopt. You adopt the collective tariff's rates and rules as your own, then file individual exceptions for rates where you differ from the collective.

Most small and mid-size movers use their own tariff because it's simpler and gives them full flexibility. If you're using a tariff management service through your industry association, make sure you understand exactly what rates you've adopted.

Regardless of which approach you use, the tariff must be kept current. When you change a rate — say, you increase your long carry charge from $95 to $125 — the tariff needs to be updated before you start charging the new rate. You should also maintain a history of past tariff versions in case a dispute arises about what rate was in effect when a particular shipment moved.

What Are the Most Common Compliance Mistakes?

1. Not having a tariff at all. Surprisingly common, especially among smaller operators who got their authority and jumped straight into moving freight without understanding the regulatory requirements.

2. Charging rates not in the tariff. This happens when dispatchers or sales reps quote ad hoc rates for accessorials that haven't been formally added to the tariff. Your CRM or quoting system should pull rates directly from your tariff schedule to prevent this.

3. Not providing the tariff to customers who request it. Under federal regulations, you must provide the tariff upon request. "We'll email it to you later" doesn't satisfy the requirement if you never follow through.

4. Outdated valuation information. Your tariff must reflect current released value and full value protection options, including the methodology for calculating depreciation if you use replacement value protection.

5. Missing SIT provisions. If you offer storage-in-transit, your tariff must include SIT rates, warehouse handling charges, and the terms for converting SIT to permanent storage. Given that SIT demand has increased significantly in recent years, this is an area where many tariffs are incomplete.

6. No effective dates on rate changes. When you modify a rate, the tariff should show the effective date of the new rate. This establishes when the rate became enforceable and protects you in disputes.

How Does the Tariff Connect to Estimates and Bills of Lading?

Your tariff is the foundation for everything that follows:

1. Estimate. When your salesperson creates a written estimate, every charge on that estimate should trace back to a tariff rate. The estimate itself is what the customer sees, but the tariff provides the legal basis for those charges.

2. Order for Service. When the customer books, the order for service confirms the estimated charges and services.

3. Bill of Lading. The bill of lading is the shipping contract between you and the customer. It references the tariff and specifies the actual charges based on shipment weight, services performed, and valuation selected.

4. Invoice. The final bill should match the bill of lading. Discrepancies between the estimate, BOL, and invoice are the #1 source of customer complaints and FMCSA enforcement actions.

When all these documents are generated from the same system using the same tariff rates, discrepancies disappear. That's a strong argument for using integrated software rather than creating each document independently.

What Happens If You're Not Compliant?

FMCSA can impose fines for tariff violations — up to $10,000 per violation. But the more common consequence is operational: a compliance review triggered by a consumer complaint that uncovers tariff issues alongside other regulatory problems. Once FMCSA is looking at your operation, they tend to find more than just the initial complaint.

Consumer complaints about billing are one of the top triggers for FMCSA investigations of household goods movers. And the first thing an investigator checks is whether your charges are supported by your tariff.

Beyond regulatory risk, tariff problems lead to chargebacks, small claims court filings, and negative reviews — all of which damage your business in ways that a fine alone doesn't capture.

Your tariff isn't a document you create once and forget about. Review it annually, update it when rates change, and make sure your sales and operations teams understand how it works. Schedule a demo to see how Elromco helps moving companies maintain compliant, consistent documentation from estimate through final invoice.