Most owner-operators think of their tariff as a PDF they generated once to satisfy an FMCSA checkbox and never opened again. That's backwards. A tariff is the single document that decides who wins when a customer disputes a bill, and federal law says you can't legally charge a rate that isn't in it.
What Does Federal Law Actually Require in a Moving Company Tariff?
Under 49 U.S.C. § 13702(c), any carrier transporting household goods must "maintain rates and related rules and practices in a published tariff," and that tariff has to be available for inspection by both the Surface Transportation Board and any shipper who asks. The implementing regulation, 49 CFR Part 1310, spells out exactly what "published" means: your tariff has to describe your services accurately, state specific rates and charges, and be "arranged in a way that allows for the determination of the exact rate, charges and service terms applicable to any given shipment" (§1310.3(a)). Vague language or a rate sheet that requires guesswork doesn't satisfy the rule.
The practical takeaway: you can't charge a customer anything that isn't in the tariff, full stop. Section 13702(a) is explicit that a carrier "may not charge or receive a different compensation for the transportation or service than the rate specified in the tariff." If your foreman quotes an extra $200 for a piano on move day and that fee isn't in your published rate table, you have no legal ground to collect it, and the customer has every ground to refuse.
What Goes Into a Compliant Tariff?
A tariff isn't just your base rate. Per §1310.3, it needs to cover every component that determines a shipment's final price:
- Base linehaul rates by weight and distance band (see linehaul charges for how these are typically structured as $/CWT tables)
- Minimum weight or charge floors so small shipments still cover fixed costs
- Every accessorial charge you might apply — stairs, long carries, shuttle service, packing, appliance servicing, storage in transit (a full breakdown lives in our accessorial charges guide)
- Fuel surcharge mechanics, if you apply one, and the formula that triggers a change
- Liability and claims terms, including your Full Value Protection and Released Value Protection options
- Any seasonal or peak-period rate adjustments
Section 1310.3(b) also allows you to split this across multiple linked documents (a base rate tariff plus a separate accessorial schedule, for example) as long as each document references the others and all of them stay available to shippers on request. That's the model most DriveSales customers actually run: a rate table for linehaul, and a separate accessorial fee schedule that the moving estimates tool applies automatically once you enter both.
How Do You Actually Publish a Tariff? Does It Need to Be Filed With Anyone?
This is where most owners get confused. You don't file your household goods tariff with the FMCSA or the Surface Transportation Board for pre-approval. There's no submission portal, no waiting period, no government sign-off. What the regulations require instead is availability and notice:
- §1310.5 requires you to keep a complete set of your effective tariffs at your principal office, make them available for inspection during business hours, and post a visible notice saying they're available.
- §1310.4 lets you incorporate tariff terms by reference into your bill of lading instead of printing the entire document on every contract — but only if the bill of lading conspicuously says the contract incorporates your tariff terms, and you make the full text available to any shipper who asks, promptly and free of charge.
- §1310.6 lets you charge a reasonable, uniform fee if someone requests a full paper copy, but you can't charge shippers for the specific incorporated terms already referenced in their own bill of lading.
Practically: publish it as a document (PDF or structured page) that lives somewhere accessible, reference it by name and version on every bill of lading, and be ready to produce the full text within 20 days if a business-office visitor asks and you don't have it on hand there (§1310.5(d)). If your rate structure changes, §1310.3(a) requires you to symbolize or highlight the change so it's identifiable, not silently swap in new numbers.
What Happens If You Skip This or Get It Wrong?
This isn't theoretical. In one FMCSA enforcement action, seven Florida-based household goods carriers were fined a combined total ranging from $7,000 to $71,000 per carrier for violations that included "failing to charge its applicable tariff rate" and, in two cases, "failing to publish a tariff" at all — alongside related failures like not providing required consumer disclosures and not preparing bills of lading correctly (FMCSA newsroom, 2002).
The dollar exposure is a lot higher today. Under the current cost-of-living-adjusted civil penalty schedule at 49 CFR § 1022.4, a general household goods regulation violation under 49 U.S.C. §14901(d)(1) carries a minimum penalty of $1,992 per violation, per day it continues. That's not a one-time fine — a tariff violation that sits unresolved for a week of operations can compound fast. The same table lists $19,941 as the minimum for a broker providing an estimate without a proper carrier agreement, and $49,848 for operating without required registration. These are minimums, not caps, and FMCSA's enforcement authority applies these per-violation, not per-carrier.
How Should You Actually Build One If You're Starting From Zero?
- Start with your linehaul structure. Decide whether you're pricing by CWT (hundredweight) and mileage band, flat hourly local rates, or both, depending on whether you run interstate, intrastate, or mixed operations.
- List every accessorial you actually charge, not just the common ones. If your crew has ever verbally quoted a fee on move day that isn't in writing anywhere, that's the gap this exercise needs to close.
- Set your minimums and surcharge triggers explicitly — don't leave "we charge extra for hard jobs" as an implied policy.
- Write the disclosure and claims language required under 49 CFR Part 375, Subpart B — how you handle complaints, whether you have an arbitration program, and what your advertising must disclose.
- Version it and date it, so a rate change is auditable rather than a silent edit.
- Reference it by name in every bill of lading and keep the full text available at your principal office.
- Feed the same numbers into your estimating software so quotes, invoices, and the published tariff never drift apart — a mismatch between what your CRM quotes and what your tariff says is exactly the gap FMCSA cites carriers for.
None of this requires a lawyer to start, but if you're running interstate authority (see our moving company license guide for the registration side of this), it's worth having counsel review the final document once before you publish it broadly.
Why a Tariff Protects You, Not Just Your Customers
Owners tend to think of tariff rules as consumer protection only. They're not. A properly published, consistently applied tariff is your best defense when a customer disputes a bill. If every charge on the invoice traces back to a rate that was published, dated, and available before the job started, you have a defensible position. If a charge was invented at the door, you don't, no matter how legitimate the underlying cost was.
This is also where DriveSales' moving estimates tooling earns its keep: instead of a rate table living in a static PDF nobody re-checks, your published rates, minimums, and surcharge rules run through the same engine that generates every quote, so the number a customer sees during the sales process, on the bill of lading, and on final invoice all come from the identical source. That consistency is exactly what §1310.3's "exact rate...applicable to any given shipment" standard is asking for.
FAQ
Do local-only (intrastate) movers need a federal tariff?
The federal tariff requirement under 49 U.S.C. §13702(c) applies to carriers subject to the Surface Transportation Board's jurisdiction, which generally means interstate household goods carriers. Intrastate movers fall under state-specific requirements instead, which vary widely — check your state's moving-industry regulator (often a Public Utilities Commission or state DOT) for the applicable rules.
Can I change my tariff rates whenever I want?
Yes, but changes must be identifiable. §1310.3(a) requires that "increases, reductions and other changes must be symbolized or highlighted in some way to facilitate ready identification of the changes and their effective dates." You can't silently edit a rate table; you need to version and date every change.
Does incorporating my tariff by reference into the bill of lading mean I don't have to show customers the details?
No. §1310.4 allows incorporation by reference instead of printing the full tariff on every contract, but only if the bill of lading conspicuously discloses that terms are incorporated, and you make the complete text available to the shipper on request, free of charge, promptly.
What's the difference between my tariff and my moving estimate?
The tariff is your published, standing rate structure. The estimate is the specific dollar figure calculated for one customer's shipment, generated by applying your tariff's rates to that shipment's weight, distance, and requested services. See our guide to creating a moving estimate for how the two connect.
What happens if my published tariff doesn't match what I actually charge?
That's a direct violation of 49 U.S.C. §13702(a), which prohibits charging "a different compensation... than the rate specified in the tariff." It's also the exact violation category FMCSA has fined carriers for historically. Keep your tariff and your billing system synchronized, ideally through the same software so there's no manual re-entry gap.
*Ready to stop reconciling rate sheets by hand? See how DriveSales' estimating engine applies your published rates automatically on every quote — book a demo to see it on your own rate structure.*
