DOT numbers for rented/leased vehicles

Scope

Legally marking all commercial motor vehicles operated by your company — including leased vehicles.

Regulatory citations

• 49 CFR 376.11 — General leasing requirements
• 49 CFR 376.12 — Lease requirements
• 49 CFR 390.21 — Marking of self-propelled CMVs and intermodal equipment

Key definitions

• Door signs: Another term for vehicle markings
• Lease: A contract or agreement in which the owner grants the use of equipment, with or without driver, for a specified period to a carrier in exchange for compensation.
• USDOT number: A number that serves as a unique identifier when collecting and monitoring a company's safety information acquired during audits, compliance reviews, crash investigations, and inspections.
• Vehicle marking: A sign or lettering on each side of a motorized CMV identifying the carrier responsible for the safe operation of the vehicle.

Summary of requirements

All commercial motor vehicles operated by your company, including rented and leased vehicles, must be legally marked. This must be done before the vehicle is operated on public roads.

General marking requirements. Each self-propelled CMV must be marked with the following:

• The legal name or a single trade name of the motor carrier operating the CMV, as listed on the Motor Carrier Identification Report (Form MCS-150) that is submitted with the Federal Motor Carrier Safety Administration (FMCSA); and
• The identification number issued to the motor carrier or IEP by the Federal Motor Carrier Safety Administration (FMCSA), preceded by “USDOT.”

If the name of a person other than the operating carrier appears on the CMV, the name of the operating carrier must be followed by the information listed above and preceded by the words “operated by.”

Other identifying information may be displayed on the CMV as long as it is consistent with the required information listed above.

All required markings must:

• Appear on both sides of the self-propelled CMV,
• Contrast sharply in color with the background on which they are placed,
• Be readily legible in daylight from 50 feet away while the CMV is stationary, and
• Be kept and maintained in a manner that retains the legibility requirements listed above.

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

Short term rental exception. A vehicle is rented for a short period of time — 30 days or less may be marked as above or 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 US DOT number;
• The rental agreement entered into by the lessor and the renting motor carrier conspicuously contains the following information:
  • The name and complete physical address of the principal place of business of the renting motor carrier, and
  • The identification number issued the renting motor carrier by the FMCSA, preceded by the letters “US DOT,” 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 motor carrier is carried on the rental CMV during the full term of the rental agreement.

The exception does not explicitly prohibit the renting again after 30 days, however, doing so would be against the intent of the exception. This regulation allows an option for marking the vehicle only. The renting/leasing carrier operating the vehicle is still responsible for compliance with all FMCSA safety regulations, as well as DOT and state permitting requirements during the term of the lease/rental agreement. Any safety or enforcement events that occur while the renting/leasing carrier is operating the vehicle are attributed to the renting/leasing carrier's US DOT number.