International: Puerto Rico

At a glanceRequirements at a glance

Moves Between Puerto Rico and the US Mainland: What Kind of Move It Is

An interstate-type move that includes an ocean leg. Ocean shipping between Puerto Rico and the mainland is domestic “coastwise” trade, which federal law (often called the Jones Act) reserves for vessels documented under US law and owned by US citizens. Federal law treats transportation to and from Puerto Rico, Alaska, Hawaii, and other territories as “noncontiguous domestic trade.”

FMCSA Operating Authority for US Mainland Moves

Yes

Required where applicable. A company that trucks household goods for hire on the mainland as part of a move to or from Puerto Rico needs FMCSA registration (a USDOT number) and household goods operating authority (an MC number), because federal motor carrier jurisdiction covers transportation between the United States and a US territory to the extent it takes place in the 50 states. The FMCSA also states that Puerto Rico is subject to its jurisdiction and that a for-hire company operating solely within Puerto Rico may still need operating authority if the goods it carries came from, or are going to, another location in the United States.

Household Goods Freight Forwarder Registration

Required where applicable. A freight forwarder, in federal terms, is a company that holds itself out to the public to move goods, takes responsibility for the shipment from origin to destination, and uses other carriers for the transportation. A mover that sells a door-to-door move between Puerto Rico and the mainland on those terms, and uses other companies’ trucks or ships, may need FMCSA registration as a household goods freight forwarder. FMCSA requires household goods carriers and household goods freight forwarders to file proof of insurance and to offer arbitration for loss and damage disputes.

Federal Consumer Protection Rules for Household Goods

Apply to the trucking on the mainland side. The FMCSA‘s household goods consumer protection rules (49 CFR part 375), covering estimates, inventories, liability options, and claims, apply to a household goods motor carrier when it carries household goods for individual shippers in interstate commerce.

FMC Licence Not Required for Puerto Rico and Mainland Ocean Moves

Under the Shipping Act, the FMC licenses ocean transportation intermediaries for trade between the United States and foreign countries. Ocean moves between Puerto Rico and the mainland are domestic trade, so the FMC’s intermediary licence does not apply to that leg. Federal oversight of water carrier rates in the noncontiguous domestic trade rests with the Surface Transportation Board (STB), not the FMC; this applies to the shipping lines rather than to movers.

FMC Licence for Moves Between Puerto Rico and Foreign Countries

Required where applicable. For FMC purposes, the “United States” includes Puerto Rico. A company based in Puerto Rico that acts as an ocean transportation intermediary (OTI) for moves to or from foreign countries must hold an FMC licence. An OTI is either a non-vessel-operating common carrier (NVOCC), which issues its own bills of lading and takes carrier responsibility without operating ships, or an ocean freight forwarder, which books cargo space and handles shipping documents for customers. A company acting only as the disclosed agent of a licensed OTI does not need its own licence.

FMC Financial Responsibility

Required for licensed OTIs. A US-based ocean freight forwarder must provide proof of financial responsibility (usually a bond) of $50,000, and a US-based NVOCC $75,000. A company that carries household goods exclusively for the US Department of Defense or under the General Services Administration’s International Household Goods Program is exempt from these FMC amounts but may face bonding requirements from those agencies.

Insurance

Required where applicable. FMCSA-registered household goods carriers and household goods freight forwarders must file proof of insurance with the FMCSA (for carriers, public liability and cargo insurance). These filings are in addition to the Puerto Rico requirements.

OverviewOverview & Scope

A mover operating only within Puerto Rico needs the NTSP authorization and other requirements on the Puerto Rico page. Moves off the island fall into two groups. Moves to or from the US mainland are domestic US moves with an ocean leg. The ocean leg is coastwise trade on US-documented vessels and is outside FMC licensing, but the trucking and forwarding are federally regulated: the company trucking the goods on the mainland needs FMCSA household goods authority, and a mover that takes door-to-door responsibility while using other carriers may need to register as a household goods freight forwarder. The FMCSA has also said that a Puerto Rico company operating only on the island may need operating authority when the goods are moving to or from the mainland. Moves between Puerto Rico and other countries are foreign commerce: a Puerto Rico company that books ocean shipping for customers or issues its own ocean bills of lading needs an FMC licence and a bond. As with domestic licences, these registrations attach to whichever company performs the regulated role. Where a mover subcontracts a leg, the carrier’s own authority covers the transport it performs, and the mover uses carriers that hold it. A mover that arranges the move in its own name may still need its own freight forwarder registration or FMC licence, as described above.

RegistrationRegistration & Compliance Essentials

Movers must:

1. Determine which role the company plays in each off-island move: motor carrier on the mainland, household goods freight forwarder, ocean transportation intermediary, or agent.
2. For moves to or from the US mainland, hold FMCSA registration (USDOT number) and household goods operating authority (MC number) if the company trucks household goods for hire as part of the move, including, as FMCSA indicates, a Puerto Rico company carrying goods that came from or are going to the mainland.
3. If the company takes door-to-door responsibility for a Puerto Rico and mainland move while using other carriers, hold FMCSA household goods freight forwarder registration.
4. Where transport is subcontracted, use carriers that hold the licences required for the transport they perform.
5. Follow the FMCSA household goods consumer protection rules (49 CFR part 375) for the interstate trucking, and offer arbitration for loss and damage disputes as FMCSA requires.
6. For moves to or from foreign countries, hold an FMC ocean transportation intermediary licence if the company acts as an NVOCC or ocean freight forwarder, unless it acts only as the disclosed agent of a licensed OTI.
7. Maintain FMC proof of financial responsibility ($50,000 for an ocean freight forwarder, $75,000 for an NVOCC), unless exempt.
8. File proof of insurance with the FMCSA where the company holds household goods carrier or freight forwarder authority.

ChecklistCompliance checklist

Company licensing

• FMCSA registration (USDOT number) and household goods operating authority (MC number)Where applicable (mover trucks household goods for hire on the mainland as part of a move to or from Puerto Rico, or, as FMCSA states, trucks within Puerto Rico goods that came from or are going to the mainland)Verified by DocumentRequired
• FMCSA household goods freight forwarder registrationWhere applicable (mover holds itself out to move household goods between Puerto Rico and the mainland, takes responsibility from origin to destination, and uses other carriers for the transportation)Verified by DocumentRequired
• FMC ocean transportation intermediary licenceWhere applicable (Puerto Rico-based mover acts as an NVOCC or ocean freight forwarder on moves to or from foreign countries, other than as the disclosed agent of a licensed OTI)Verified by DocumentRequired
• FMC proof of financial responsibility ($50,000 ocean freight forwarder, $75,000 NVOCC)Where applicable (mover holds an FMC OTI licence and is not exempt as a DoD or GSA household goods carrier)Verified by DocumentRequired
• Proof of insurance filed with the FMCSAWhere applicable (mover holds FMCSA household goods carrier or freight forwarder authority)Verified by DocumentRequired

Subcontracted transport

• Where transport is subcontracted, the mover uses carriers that hold the licences required for the transport they performWhere applicableVerified by AffirmationRequired

Customer practices

• FMCSA household goods consumer protection rules (49 CFR part 375) followed, and arbitration offered for loss and damage disputesWhere applicable (mover acts as a household goods motor carrier or freight forwarder for individual shippers on the mainland leg)Verified by AffirmationRequired