The Cold Chain: Understanding how produce pays, and what it means for your DSO

This next article in our Cold Chain series drills down into PACA and how it affects payment for produce loads.

Brad Guinane
September 21, 2026

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23 minute read

If you move fresh food, or you’re considering adding it to your book, the payment side of the business deserves as much attention as the lanes and the rates.

Produce operates under federal law, the Perishable Agricultural Commodities Act (PACA), which has no real equivalent elsewhere in freight. This law shapes when you get paid, how disputes over condition are resolved, and where you stand if a customer goes under. 

What follows is a walk through those mechanics. If you’ve been hauling produce for 20 years, a fair amount of this will be familiar, though the question of where transportation sits relative to the PACA trust surprises many experienced operators. If you’ve never moved a load of produce, nothing here assumes that you have. 

One term is worth setting up front, since everything else connects back to it: DSO, or days sales outstanding, is the average number of days between sending an invoice and collecting the money. It’s the standard way to measure how long your cash sits in someone else’s hands.

I spent a decade in general freight before coming to fresh food, and the payment mechanics were the first thing I wanted to understand properly. This is what I found. 

In general freight, collecting is generally the harder half of the transaction.

How Payment Works in the Rest of Freight 

It helps to start with a baseline, because produce only looks unusual next to what most providers are used to. In general freight, collecting is generally the harder half of the transaction.

A Bloomberg and Truckstop survey for the first half of 2026 asked 141 brokers how long their shippers take to pay. Just under half, 48 percent, said three to four weeks. Another 30 percent said a month or more. Fewer than one in 10 collect inside a week. 

The other side of the same transaction moves considerably faster. In that survey, 56 percent of brokers reported that carriers at least sometimes ask about payment terms or quick pay, which is an accelerated payment option in exchange for a small discount, before they will accept a load.  

The pattern this creates is familiar to anyone who has run a brokerage: you pay quickly to secure the truck, you collect slowly from the customer, and you cover the difference out of your own working capital in the meantime. 

The cost of covering that difference has risen sharply this year. The national average price for on-highway diesel reached $6.285 a gallon during the week of September 15, the highest figure in a series the Energy Information Administration has kept since 1994.  

It rose sharply and has continued to climb largely because the Iran conflict has tightened global fuel supply. Refrigerated spot rates, quoted all-in with fuel included, averaged $3.54 a mile heading into Labor Day.

Higher fuel and higher rates both mean larger invoices, and a larger invoice ties up more cash for every day it goes unpaid.

Higher fuel and higher rates both mean larger invoices, and a larger invoice ties up more cash for every day it goes unpaid. 

The arithmetic is worth running against your own numbers. A company billing $10 million a year with a 50-day DSO has roughly $1.4 million of its cash sitting in customer receivables at any given moment.

At 60 days, that figure is about $1.6 million. So 10 days of DSO, in other words, is worth a couple hundred thousand dollars of working capital on a book that size. 

Produce is the exception to much of this, and not because anything changed recently. It’s the one segment of freight where the payment clock is set by federal statute rather than negotiated customer by customer, and it’s been set at 10 days since 1930.

Where the Rules Came From 

The reason produce has its own payment law comes down to a simple commercial problem: the product does not keep. 

When a buyer fails to pay for a load of steel, the steel still exists and can be recovered or resold. When a buyer fails to pay for a load of romaine, there’s nothing left to repossess, and the grower has lost an entire season of work with no recourse.  

Congress addressed this in 1930 with PACA and returned to the problem in 1984, adding a statutory trust after a series of buyer bankruptcies left produce sellers with nothing while other creditors were made whole. 

The resulting framework is fairly straightforward once you see it laid out. Payment for produce is due within 10 days of acceptance. Buyers and sellers can agree in writing to longer terms, and doing so does not violate the Act.

However, only terms of 30 days or less preserve the seller’s trust protection. A seller who agrees to 45-day terms has made a perfectly legal arrangement but has given up the trust in the process. 

The trust is the mechanism that makes this industry pay on time.

The trust is the mechanism that makes this industry pay on time. Under it, a produce buyer holds its inventory, anything made from that inventory, and the money received from selling it, in trust for the suppliers it has not yet paid.  

A supplier who has preserved its rights is paid from those assets ahead of the buyer’s bank. Preserving those rights requires specific statutory language printed on invoices, which is the origin of the dense paragraph you’ve probably seen at the bottom of every produce invoice crossing your desk. 

This is why produce customers tend to pay faster than general freight accounts. It’s not a matter of industry culture or regional custom. It’s 90 years of law shaping how the money moves and is one of the genuine advantages of working in this segment. 

Where a Transportation Provider Fits In 

Here the framework becomes less intuitive and is the part most worth understanding before you commit to growing a produce book. 

The PACA trust protects sellers and suppliers of produce. It was not drafted to cover the companies transporting that produce, and the courts have interpreted that boundary narrowly. 

The question came before the Third Circuit in 2006 on facts that will sound familiar to anyone in this business. A logistics company had arranged and paid for transportation on seven produce shipments to a buyer that subsequently failed, leaving $39,200 in freight charges unpaid.  

The company asked to be paid from the PACA trust alongside the produce sellers. The court declined, reasoning that Congress had intended the trust to protect sellers and suppliers of produce, and transportation services, however necessary, were ancillary to the sale itself. 

It would be easy to read this as the law disfavoring transportation, but the reasoning is more practical.

It would be easy to read this as the law disfavoring transportation, but the reasoning is more practical. The trust is a powerful remedy precisely because it’s narrow. If it extended to every vendor who touched a load, the pool would be spread thin enough that it would no longer accomplish what it was created to do for growers. 

What this means in practice is manageable, provided you know it in advance rather than learning it during a customer’s bankruptcy. Your customers operate inside a protective structure. Your freight invoice sits outside of it.

Your protection therefore comes from selecting customers carefully rather than from the statute, and customer selection is something you have real control over. 

What It Looks Like for Brokers and Carriers

The same rules land differently depending on where you sit in the transaction. 

A broker is funding both ends at once, paying the carrier on net-7 or quick pay terms while collecting from the shipper or receiver on whatever was agreed. In produce, that gap tends to be narrower than in general freight, which works in your favor.  

The complication appears under stress. If a receiver disputes the condition of a load and withholds part of the invoice, your obligation to the carrier does not pause while it gets sorted out.

You’re paying on schedule against a receivable that’s frozen behind a claim you may have had no part in creating. 

An asset carrier’s exposure runs through whoever holds the freight bill.

An asset carrier’s exposure runs through whoever holds the freight bill. If you’re billing a broker, your payment depends on that broker’s own collection cycle and balance sheet, including the situation just described. 

If you’re billing a produce shipper directly, you’re closer to the source of the money but operating inside the same dispute mechanics, where a claim is more likely to show up as a deduction from your invoice than as a separate proceeding. 

Neither situation argues against taking the freight. Both argue for knowing which customers you’re taking it from. 

How Disputes Affect Payment Timing 

The mechanic that moves DSO most in produce is the one governing disputes, and it follows directly from the regulation. 

The 10-day payment clock applies only to the undisputed portion of a transaction. It’s a fast clock, but it stops at the boundary of any disagreement, and whatever is in dispute falls outside of it until the disagreement is resolved. 

The speed at which these disputes arise is worth appreciating as well. A receiver has up to eight hours after being notified of arrival, once the product is accessible for inspection, to reject a truckload of fresh produce.

Decisions about condition are therefore made on the dock and made quickly, frequently before anyone has called you about it.

This is where produce departs most clearly from the rest of freight. In a typical general freight transaction, the invoice is paid on its own schedule and a cargo claim proceeds separately. 

In produce, condition is not a side issue but the substance of the transaction.

In produce, condition is not a side issue but the substance of the transaction.

A temperature excursion or a delay in transit does not become a separate claim so much as it becomes a disputed amount, and disputed amounts are exactly what the payment clock does not cover. 

You retain your rights under the Carmack Amendment, the federal statute governing carrier liability for cargo loss and damage, and you may well prevail on the merits. But resolution takes time, and that time registers in your DSO regardless of how the claim eventually turns out. 

One deadline is worth committing to memory, because it’s easy to miss while a dispute drags on. A PACA reparation complaint must be filed with the USDA within nine months of when the cause of action accrues.  

Informal back-and-forth over a disputed invoice can consume that window without anyone intending it to, and the right to file does not survive it. Whatever else you do with a stalled account, track the nine months. 

It’s also worth knowing that condition disputes in this industry are not argued in a vacuum. Blue Book publishes the Trading and Transportation Guidelines, which set out what accepted practice looks like on questions like suitable shipping condition, temperature, and transit time.  

Having a written industry standard to point at changes the character of these conversations, because both sides are arguing from the same reference rather than from whoever is more forceful on the phone. 

It helps to think of DSO in this segment as two separate measures reported as one. 

The Two Components of Produce DSO 

It helps to think of DSO in this segment as two separate measures reported as one, because most providers actively manage only the first. The first is how quickly a customer pays an invoice nobody is arguing about. The second is what proportion of your invoices remain free of disputes in the first place. 

Consider two accounts. One pays in 22 days but contests roughly one load in six. The other pays in 38 days and never raises an issue.  

Depending on the size of the disputes, the faster payer may well be the more expensive customer, and a blended DSO figure will show a reasonable average while obscuring the fact that your steady account is quietly carrying the difficult one. 

Both components are largely determined before the load moves, and neither is easy to change afterwards. This is inconvenient in one sense and encouraging in another, because it means the useful work happens at the point where you still have choices.  

The question is what you can actually find out at that point, and in fresh food the answer is more than most providers expect. 

Four Practices Worth Adopting 

Underwrite the customer, not only the lane. Rate, volume, and lane density tell you what an account is worth, assuming it pays. Credit history and payment behavior tell you how safe that assumption is. In many organizations, these two assessments happen in different departments on different timelines, which is how an attractive lane ends up attached to a slow-paying receivable. 

Put payment terms in writing before the first load. Your produce customers already work this way, since the regulations require written agreements for anything other than the default terms. Asking for the same is a normal and unremarkable request in this industry, and it’s a considerably easier conversation to have before a dispute than after one. 

Document condition as though you will need to prove it.

Document condition as though you will need to prove it. Reefer downloads, pulp temperatures taken at both origin and destination, seal records, timestamps, and photographs. Given how quickly a receiver can reject a load, this documentation is less about winning an argument months later than about keeping an amount from being disputed at all. 

Track payment behavior over time rather than checking it once. A credit check taken at onboarding is a snapshot of a single moment. A customer who paid consistently in 28 days for two years then drifted to 51 is signaling a change worth noticing, and they’re almost certainly signaling it to every other provider hauling their freight at the same time. 

What You Can See Before You Commit 

Everything above describes risk that becomes difficult to manage once a load is moving. What makes fresh food genuinely different from general freight is how much is visible beforehand. 

In general freight there’s no shared record of how a shipper pays. Each broker and carrier discovers it independently, by hauling and waiting to find out. Fresh food built that record a long time ago, because perishability forced this industry to confront counterparty risk before other sectors had to.  

What makes that record unusual is where it comes from: companies in the network submit their own accounts receivable aging files and trade experiences.

The information reflects what trading partners have actually collected rather than what an outside database has inferred. Which means both components of produce DSO have somewhere to look. 

For how quickly a customer pays a clean invoice, there are several reads on the same company rather than one grade.

For how quickly a customer pays a clean invoice, there are several reads on the same company rather than one grade.

A predictive credit score updated daily, a pay rating drawn from the network, trade experiences reported by members who have actually sold to the company, a trade activity score showing six-month momentum rather than a static number, and full rating history instead of a snapshot.  

The distinction between a snapshot and a trend, which I raised a few paragraphs ago, is the entire point of the last two. 

For what share of your invoices stay clean, there’s something general freight has no equivalent to. Every firm listed carries a Claims Activity Table showing claims filed against it in the last two years, along with any claim found meritorious in the last five.  

It’s easy to think of it as something you might use against a customer who will not pay, but it reads just as well in the other direction, as a screening tool before you extend terms at all. A receiver who routinely contests condition has usually contested it with somebody who filed. 

What to Do When an Invoice Stalls Anyway 

Due diligence reduces the problem but does not eliminate it. Some portion of your receivables will age past terms no matter how carefully you select accounts.

But it’s worth knowing there’s a graduated path rather than a binary choice between writing it off and calling a lawyer. 

The first step is a “Courtesy Contact,” which is a note sent on your behalf asking the customer for a status update. It doesn’t appear in the Claims Activity Table or on the credit file, no claim has been filed, and it’s not a credit rating event.

For a customer you intend to keep working with, this distinction matters.

For a customer you intend to keep working with, this distinction matters, and many past-due balances resolve here without going further. 

The second is a filed claim, worked by the Claims, Collections & Dispute Resolution team, and is assessed for merit based on documentation from both sides. The leverage here is not the filing itself but where it appears.  

An open claim shows up in the Claims Activity Table other companies read when deciding whether to extend credit to that same customer. A debtor under pressure doesn’t stop paying everyone. They make choices, and being visible in the place those choices get made changes where you sit in the order. 

The third is formal escalation through PACA, outside collections, or counsel. Nothing you do at the first two steps forfeits this one, which is why the sequence is worth using in order. Just keep the nine-month clock in view. 

There’s also a middle path that gets overlooked. Not every past-due balance is a bad debt.

Often it’s a genuine disagreement about condition or performance, and a neutral party assessing it against the published Trading and Transportation Guidelines is worth more than a demand letter. The counterparty you keep is usually worth more than the invoice you win. 

The Numbers You Already Track 

To anyone reading this, DSO is not a new metric. Every transportation CFO tracks it, reports it, and closes the month on it.  

What produce changes is how much of it is settled before a load moves, and how much of that is knowable in advance.

The more useful question is not what the number was last quarter, but whether it could have been anticipated. In fresh food, more often than in any other segment of freight, it can be. 

The records and services described here sit inside Blue Book membership, which added a transportation-specific subscription in June alongside a professional certification for fresh food freight. Blue Book published its first transportation guidelines in 1971 and began recognizing Transportation Members in 1973. 

Sources and Authorities 

Prompt payment. Payment for produce purchased by a buyer is due within 10 days after the day the produce is accepted: 7 CFR 46.2(aa)(5). Parties may agree to different payment timing in writing before the transaction: 7 CFR 46.2(aa)(11). 

Disputed amounts. Where a transaction is in dispute, the prompt payment periods apply only to the undisputed amount: 7 CFR 46.2(aa). 

Trust eligibility. Only transactions with payment terms of 30 days or less from receipt and acceptance qualify for PACA trust protection: 7 CFR 46.46(e)(2). The statutory trust itself is at 7 U.S.C. § 499e(c), added by the 1984 amendments to the Act. 

Preserving trust rights. A licensed seller may preserve its trust rights by including the required statutory language on the face of its invoice: 7 CFR 46.46(f). 

Rejection window. For truck shipments of fresh fruits and vegetables, a reasonable time to reject is not to exceed 8 hours after the receiver is given notice of arrival and the produce is made accessible for inspection: 7 CFR 46.2(cc)(2). 

Transportation providers and the trust. Pacific International Marketing, Inc. v. A & B Produce, Inc., 462 F.3d 279 (3d Cir. 2006), holding that Exel Transportation Services, which arranged and paid for transportation of produce, could not recover its freight charges from the PACA trust because Congress intended to protect sellers and suppliers of produce, not third-party service providers whose services are ancillary to the sale. 

Carrier liability. Carmack Amendment, 49 U.S.C. § 14706. 

Reparation deadline. A PACA reparation complaint must be filed with the Secretary of Agriculture within nine months after the cause of action accrues: 7 U.S.C. § 499f(a). 

Market data. Bloomberg and Truckstop broker survey, first half 2026 (n=141). EIA national average on-highway diesel price, week of September 7, 2026 ($5.967, a record for the weekly series begun in March 1994; figure is nominal and not inflation-adjusted). DAT reefer all-in spot rate, week of August 30 to September 5, 2026. 

Part 46 of the PACA regulations is current as of September 2026 and has not been amended since March 2018. This article is general information, not legal advice.

Brad Guinane is president of Blue Book's Supply Chain Solutions division.

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