To allow the motoring public and enforcement officers to easily identify the carrier that is responsible for the safe operation of any commercial motor vehicle (CMV), the vehicle must be marked on both sides with the carrier’s U.S. Department of Transportation (USDOT) number and the carrier’s name.

• Where a vehicle operates will dictate whether it is subject to federal or state rules.
• Companies that operate commercial motor vehicles that transport passengers or cargo in interstate commerce must register with the Federal Motor Carrier Safety Administration to obtain a U.S. Department of Transportation Number.
• Additionally, intrastate carriers that transport hazardous materials that require a safety permit must register for a U.S. Department of Transportation Number.

Determining which vehicles need to display identification and what information must be shown can be confusing.

Several factors influence the answer to these questions. First, where does the vehicle operate? Traveling across state lines or furthering interstate commerce subjects the vehicle to Federal Motor Carrier Safety Administration (FMCSA) rules.

Operating solely within a single state, never crossing state lines, and not furthering interstate commerce is �intrastate� transportation, governed by the state of operation.

Second, certain characteristics of the vehicle or load affect which vehicles must display identification. These characteristics include gross vehicle (or combination) weight/rating, number of passengers, or if the vehicle is transporting placardable hazardous materials.

All vehicles defined as commercial motor vehicles (CMVs) in 390.5 and operating in interstate commerce must display the identification information according to 390.21.

The vehicle marking must show:

• The legal name or single trade name of the company operating the vehicle, and
• The motor carrier (MC) identification number, issued by the FMCSA, preceded by the letters �USDOT.�

There are no size and spacing requirements other than the marking is readily legible during daylight hours from a distance of 50 feet, and the letters must contrast sharply in color with the background on which the letters are placed.

If a vehicle that travels interstate meets the definition of a CMV, it must have the USDOT number and legal company name displayed on the vehicle as required by the FMCSA marking requirements in 390.21. Both for-hire and private carriers must comply. Note that transporters of placardable amounts of hazardous materials must comply regardless of weight.

Who needs a USDOT number?

Any company that operates commercial motor vehicles (CMVs) that transport passengers or cargo in interstate commerce must register with the Federal Motor Carrier Safety Administration (FMCSA) to obtain a U.S. Department of Transportation (USDOT) Number. In addition, intrastate carriers that transport hazardous materials that requires a safety permit must register for a USDOT Number.

Rather than creating a unique tracking mechanism and numbering system, 36 states also require carriers that operate strictly in intrastate commerce to obtain a USDOT number.

A USDOT number is a unique identifier used to collect data and monitor a company�s safety information acquired during audits, compliance reviews, crash investigations, and inspections. All violations found at roadside inspections are recorded to the operating carrier�s USDOT number.

• Companies must file an MCSA-1 with the Federal Motor Carrier Safety Administration using the Unified Registration System and receive a U.S. Department of Transportation number to begin operations as an interstate carrier — or as an intrastate carrier transporting hazardous materials requiring a safety permit.
• The new entrant registration process requires motor carriers to be subject to an 18-month monitoring period. The carrier’s roadside safety performance will be closely monitored during this period to ensure their basic safety management controls are operating effectively.
• A carrier’s permanent authority begins at the end of the 18-month monitoring period when they pass the safety audit and do not have any outstanding civil penalties.

To begin operations as an interstate carrier — or as an intrastate carrier transporting hazardous materials requiring a safety permit, the company must file an MCSA-1 with the Federal Motor Carrier Safety Administration (FMCSA) using the Unified Registration System (URS) and receive a U.S. Department of Transportation (USDOT) number. Once activated, this number or registration allows the company to operate commercial vehicles. It will not be activated until all the initial filing requirements are completed. The initial registration form is much more in-depth than the subsequent required updates.

Registration requires basic company demographics to be provided. This information is not directly used for safety scoring but does provide information that is helpful to the FMCSA for studies and investigations.

The full legal business name as it appears on the articles of organization, or the complete corporate name as it appears on the incorporation certificate must be included in the registration – complete with any suffixes. The name cannot be a related entity or a tradename, the FMCSA needs to know the entity that is responsible for the safe operation of the vehicles.

The form also allows a separate entry of a single trade name or doing business name (DBA). This entry can have a benefit in how the vehicles are marked. When the tradename or DBA is included on the registration, the vehicles can be marked with either the legal name or the trade name. Before including a tradename on the registration, be aware that tradename laws can vary from state to state.

This principal address on the form must be a physical address (not a P.O. box). This is the address used by FMCSA for on-site visits for the purpose of conducting safety audits, investigations, and other activities. For this reason, it cannot be the address of a consultant, service agent, or an attorney unless they also engage in operations at that location. If the mailing address is different than the physical address, there is another line to include it.

What is the new entrant process to become a motor carrier?

After being issued a new entrant registration, the carrier is subject to an 18-month safety-monitoring period. During this safety monitoring period, the carrier’s roadside safety performance will be closely monitored to ensure the carrier’s basic safety management controls are operating effectively. Also, during this safety-monitoring period, the motor carrier (MC) will receive a safety audit.

A safety audit will be conducted on the new entrant once it has been in operation for enough time to have sufficient records to allow the agency to evaluate the adequacy of its basic safety management controls. This period will generally be at least three months. Typically, the safety audit occurs within the first 12 months of operation.

The carrier may be subjected to an expedited safety audit or compliance review if any of seven violations listed in 385.308 are discovered during a roadside inspection or by any other means.

The violations include, but are not limited to, using a driver who does not possess a valid commercial driver’s license, operating a vehicle placed out of service, being involved in certain hazardous materials reportable incidents, and operating a commercial motor vehicle (CMV) without appropriate levels of financial responsibility. The entire list of violations may be found in 385.308.

The safety audit will be conducted by a state or federal auditor who will review the carrier’s safety management system. The areas of review include, but are not limited to, the following:

• Driver qualification;
• Driver duty status;
• Vehicle maintenance;
• Accident register; and
• Controlled substances and alcohol use and testing requirements.

The FMCSA will notify the carrier of the results of the safety audit within 45 days.

If FMCSA determines the new entrant has adequate basic safety management controls, the new entrant will be notified and will continue to be monitored for the remainder of the 18-month safety-monitoring period.

If FMCSA determines the new entrant does not have adequate basic safety management controls, the new entrant will be notified that its new entrant registration will be revoked and its operations placed out of service unless the new entrant takes specific actions to remedy its safety practices.

A new entrant will automatically fail a safety audit and will receive notice that its USDOT new entrant registration will be revoked if found in violation of any of one of 16 regulations listed in 385.321.

These violations include, but are not limited to, non-compliance with alcohol and controlled substance regulations, using a driver who does not possess a valid commercial driver’s license, using an unqualified driver, and failing to require a driver to complete a daily log. The entire list of violations may be found in 385.321.

All new entrant MCs must complete an application package consisting of an MCSA-1 online-only form. The online form is available at fmcsa.dot.gov/registration. This online-only form was the result of the FMCSA’s URS.

For-hire MCs must also pay a $300 filing fee to obtain regulated for-hire carrier authority.

Once the application package is completed, the carrier will be granted new entrant registration (USDOT number).

Electronic filing is available using the Safer System at http://safer.fmcsa.dot.gov/.

The regulations governing registering as a new entrant are found at 385 Subpart D. The Safety audit criteria is found in 385 Appendix A.

When does a new entrant status end and permanent authority begin?

A new entrant will be notified in writing that new entrant designation will be removed from their registration at the end of the 18-month safety-monitoring period if the following are true:

• The carrier passes the safety audit or has not been deemed unfit following a compliance review; and
• The new entrant does not have any outstanding civil penalties.

• A U.S. Department of Transportation (USDOT) number is unique to an individual carrier.
• U.S. Department of Transportation numbers are not transferable and are assigned to one person (individual, corporation, partnership, etc.), forever.
• The Federal Motor Carrier Safety Administration does not prohibit additional information on the vehicle, but at the federal level, additional markings are not required.
• Interstate vehicles only need to be marked when meeting the definition of a commercial motor vehicle, so some carriers use temporary magnetic or vinyl signs so the vehicle is only marked when regulated by the federal motor carrier safety regulations.

As a federal employer identification number (FEIN) is unique to a corporate entity, a U.S. Department of Transportation (USDOT) number is unique to an individual carrier.

Multiple USDOT numbers can never be created for the purpose of evading statutory or regulatory requirements, a Federal Motor Carrier Safety Administration (FMCSA) order, enforcement action, or negative compliance history.

There should be a one-to-one relationship between an FEIN and a USDOT number. The FMCSA strongly prefers that individual terminals or divisions that are not a legal entity, report through a single corporate USDOT number. This also means that related entities cannot share a USDOT number.

Are divisions and subsidiaries of a corporate entity allowed to have separate USDOT numbers?

The agency states that �USDOT numbers are not transferable and are assigned to only one person and remain assigned to that person forever. A person includes an individual, corporation, partnership, or other business organization as authorized by state law. Each separate and distinct person must have separate registration.� Are divisions and subsidiaries of a corporate entity allowed to have separate USDOT numbers? Each legal entity needs to have its own USDOT number. The number cannot be shared among related separate entities.

The FMCSA will consider requests for assignment of individual USDOT numbers to corporate divisions on a case-by-case basis.

The FMCSA has provided this information for guidance.

Question: Should each terminal operation or branch of a corporation register for a USDOT number?

Answer: A USDOT number usually applies to the company, not a particular branch office or vehicle. Generally, the corporate office or headquarters should register the company and should inform its branches of the USDOT number. For companies with multiple branches, maintaining proper registration with the FMCSA requires good communication between the corporate headquarters and the terminal offices. The company�s headquarters can then interact with the FMCSA to ensure that all of its branches are properly accounted for.

Can other identifying information be displayed on a CMV?

The Federal Motor Carrier Safety Administration (FMCSA) does not prohibit additional information on the vehicle, but at the federal level, additional markings are not required.

Do the marking regulations require the display of city and state on CMVs?

The federal marking regulations no longer require motor carriers (MCs) to mark their motor vehicles with the city and state. However, the rules do not prohibit showing the address along with the required carrier name and U.S. Department of Transportation (USDOT) number.

While the federal requirements do not require an address, a state or local municipality may. The most prevalent example of this is New York City.

Can the MC number be displayed?

Interstate for-hire carriers may not display their Interstate Commerce Commission Motor Carrier (ICC-MC) number instead of their USDOT number. These carriers are required to have operating authority and an MC number, but they must display the USDOT number on all vehicles. Carriers are not required to remove existing MC number markings but are encouraged not to display the MC number on new or repainted commercial motor vehicles (CMVs). The FMCSA prefers that carriers phase out MC numbers on vehicles as new vehicles are purchased or repainted.

Does a USDOT marking have to be painted on the vehicle?

The marking may be painted on the CMV or may consist of a removable device that meets the identification and legibility requirements of 390.21.

Since interstate vehicles only need to be marked when meeting the definition of a CMV, some carriers use temporary magnetic or vinyl signs so the vehicle is only marked when regulated by the federal motor carrier safety regulations (FMCSRs).

What are the vehicle marking requirements in Canada?

Canada�s vehicle marking requirements are established by each jurisdiction; there isn�t one applicable standard like there is in the U.S. regulations.

To view each Canadian jurisdiction�s vehicle marking requirements, click here <<link will go to province-by-province content in RegSense>>

• Rental vehicles rented for 30 days or less may be conditionally marked with the rental company’s name and U.S. Department of Transportation number.
• An owner operator that is leased to a carrier must display the markings (name and U.S. Department of Transportation number) of the carrier – even if the operator has their own U.S. Department of Transportation number.
• Intermodal equipment must be marked with or otherwise identifiable via a U.S. Department of Transportation number.

Rental vehicles

All commercial motor vehicles (CMVs) operated by a carrier must be legally marked with the company name as listed on the MCS-150 and the carrier’s U.S. Department of Transportation (USDOT) number. This must be done before the vehicle is put into service and operated on public roads.

A vehicle is rented for a short period of time – 30 days or less may be marked with the rental company’s name and USDOT number. To qualify for the exception:

• The vehicle is rented for 30 days or less;
• The vehicle is properly marked with the rental company’s legal name and USDOT number;
• The rental agreement entered into by the lessor and the renting motor carrier (MC) conspicuously contains the following information:
  • The name and complete physical address of the principal place of business of the renting MC, and
  • The identification number issued the renting MC by the Federal Motor Carrier Safety Administration (FMCSA), preceded by the letters “USDOT,” and
  • The sentence: “This lessor cooperates with all Federal, State, and local law enforcement officials nationwide to provide the identity of customers who operate this rental CMV;” and
• The rental agreement entered into by the lessor and the renting MC is carried on the rental CMV during the full term of the rental agreement.

Leased driver’s vehicles

The U.S. Department of Transportation (USDOT) number is used by the Federal Motor Carrier Safety Administration (FMCSA) and the States to identify motor carriers and monitor their safety performance. Owner-operators leased to a carrier operate under the carrier’s authority and USDOT number. There is no need for the owner-operator to have a separate USDOT number unless the owner operator will also operate as a carrier under their own authority.

An owner operator that is leased to a carrier must display the markings (name and USDOT number) of the carrier – even if the operator has their own USDOT number.

Intermodal equipment

Intermodal equipment must be marked with or otherwise identifiable via a U.S. Department of Transportation (USDOT) number. Under 390.21(g)(4), intermodal equipment providers have five options for identifying their intermodal equipment. In all cases, the identification must include the provider’s legal name or single trade name and the Federal Motor Carrier Safety Administration (FMCSA) identification number preceded by “USDOT.” Any one of the following five options will satisfy the identification requirement:

• Marking the identification on the curb side of the item of equipment. The marking must be in letters that contrast sharply in color with the background on which the letters are placed. The identification code must be readily legible, during daylight hours, from a distance of 50 feet while the vehicle is stationary. It must be kept and maintained in a manner that retains this legibility.

• Placing the identification marking on a label placed upon the curb side of the item of equipment. The label must be readily visible and legible to an inspection official during daylight hours when the vehicle is stationary. The label must be a color that contrasts sharply with the background on which it is placed, and the letters must also contrast sharply in color with the background of the label. The label must be kept and maintained in a manner that retains this legibility.
• Marking the interchange agreement. The USDOT number of the intermodal equipment provider, as well as the vehicle identification number (VIN) and 4-character Standard Carrier Alpha Code (SCAC) code and 6-digit unique identifying number, must be placed on the interchange agreement so that it is clearly identifiable to an inspection official.
• Placing the identification information on a document placed in a weather-tight compartment affixed to the frame of the intermodal equipment. The color of the letters used in the document must contrast sharply in color with the background of the document. The document must include additional information to identify the specific item of equipment (such as the VIN and 4-character SCAC code and 6-digit unique identifying number).
• Maintaining the USDOT number in a database. The database must be available via real-time internet and telephone access and must identify the name and USDOT number of the intermodal equipment provider responsible for the intermodal equipment. Database inquiry methods must include (a) SCAC plus trailing digits, (b) license plate number and state of license, or (c) VIN of the item of intermodal equipment. The database must offer read-only access without requiring advance user registration, a password, or a usage fee.