The Federal Motor Carrier Safety Administration published a notice in Tuesday’s Federal Register that most people in trucking will ignore. It’s a routine paperwork exercise: an information-collection renewal for CMV marking requirements under Docket No. FMCSA-2025-1381. The agency wants to continue documenting the burden of requiring carriers to place their names and USDOT numbers on the sides of their trucks.
FMCSA estimates 938,861 respondents are affected by these marking rules, including 900,043 freight-carrying motor carriers, 20,878 intrastate hazmat haulers, 16,409 passenger carriers and 1,531 intermodal equipment providers. The agency calculates that these entities spend a combined 4.69 million hours annually affixing USDOT numbers and carrier names to their equipment. I’d argue chameleon carriers spend a lot more time with their daily marking swaps of identifiers.
The renewal shows a decrease of 2.5 million estimated annual burden hours from the previously approved calculation. FMCSA attributes this to “adjustments in respondent and response estimates.” Translation: they were overcounting something, or the industry shrank, or both.
What the notice doesn’t mention is how those marking requirements are actually working in the real world. Spoiler: not great.
In 2024, violations of 49 CFR 390.21 were among the top five most-cited violations nationwide during roadside inspections. Over 153,000 instances of marking violations were recorded. The specific violation for the carrier name or USDOT number not displayed as required was cited more than 42,000 times. That’s 42,000 times an officer stood next to a truck and couldn’t verify who was operating it.
That’s just the stuff that gets caught.
The chameleon carrier problem
Ask anyone in carrier vetting and they’ll tell you marking requirements are being gamed. Private sector companies like DAT, Genlogs and others have built proprietary systems specifically to flag carriers displaying behaviors inconsistent with their registered information. These tools exist because the federal registration system has holes.
Chameleon carriers, those operators who repeatedly shut down and reopen under new names to evade enforcement, have turned vehicle marking into an art form. According to a Government Accountability Office report, carriers with chameleon attributes are three times more likely than legitimate new applicants to be involved in severe crashes. Three times.
Drivers keep folders in their cabs, each with a different USDOT number printed on a magnetic or paper placard. When they roll under one carrier’s authority, they slap on that number. When they switch to another, they swap the magnet. Some carriers buy existing USDOT numbers through Facebook groups, Telegram messenger apps and online forums, then change the contact information to assume the identity. They operate under that authority without completing proper registration, sometimes to hide violations and revoked authority from their other USDOTs.
A leaked Department of Transportation memo from November 2025 revealed the agency’s internal analysts had identified “behavioral patterns that mirror the tactics used by high-risk carriers attempting to disguise operational identity.” The patterns include shared addresses, rapid DOT number turnover, duplicate contact information, inconsistent equipment reporting and clusters of nearly identical companies in the same commercial corridors. The memo called these “systemic weaknesses” that unsafe operators keep exploiting.
Carrier identity theft
There’s another marking fraud that doesn’t get enough attention, and it’s arguably worse than chameleon carriers because the victim isn’t just the motoring public. It’s a legitimate carrier that has no idea they’ve been compromised.
A bad actor obtains a legitimate carrier’s information, often publicly available through SAFER or other databases. They create a forged lease agreement complete with the carrier’s name, USDOT number and address. They tape or magnet the carrier’s markings onto their truck. Now they’re operating under a stolen identity, and the real carrier doesn’t know it’s happening.
When that truck is inspected, any violations are recorded against the victim carrier’s USDOT number. The legitimate carrier’s CSA scores take the hit. Their insurance rates potentially increase. They may receive warning letters from FMCSA about violations they never committed, on equipment they’ve never seen, involving drivers they’ve never employed.
If that fraudulently marked truck causes a crash, the scrutiny falls on the legitimate carrier first. They have to prove a negative, demonstrate that this person, this truck, this load had nothing to do with their operation. Meanwhile, plaintiff’s attorneys are pulling their safety records, their inspection history, and their driver files. The carrier is defending itself against an accident that occurred in a state it doesn’t even operate in, involving a driver whose name it’s hearing for the first time in a deposition.
The forged lease agreement is the key. When an officer asks for documentation during a roadside inspection, the fraudster produces what appears to be a legitimate lease. The officer has no practical way to verify that document in real time. They record the USDOT number displayed on the truck, and that number is entered into MCMIS, attached to any violations discovered. The real carrier won’t know until the DataQs start piling up or until they get a call from a claims adjuster asking about an accident they’ve never heard of.
This isn’t theoretical it happens every day, and the marking requirements that are supposed to help identify who’s operating a vehicle are being weaponized against carriers who played by the rules.
Legitimate operators caught in the middle
Some legitimate marking changes happen constantly in trucking.
When an owner-operator leases onto a carrier, FMCSA considers them an extension of that carrier for compliance purposes. The regulations require the owner-operator’s truck to display the carrier’s name and USDOT number, even if the driver has their own authority. If the owner-operator ends that lease and signs with another carrier, the markings have to change. If they run under their own authority sometimes but lease on for specific loads, more changes.
The rules say only one USDOT number may be visible on the vehicle at any time. Vehicles leased for more than 30 days must display the operating carrier’s information. If the rental company’s name is on the truck, the operating carrier’s info must be preceded by “operated by.”
This creates a practical problem for small fleets and owner-operators who work with multiple motor carriers. Permanent vinyl lettering becomes impractical. Magnetic signs become necessary. And once you’re using removable markings, you’re using the same tools the fraudsters use.
The visual difference between a legitimate owner-operator swapping magnets to reflect his current lease agreement and a chameleon carrier swapping placards to hide from enforcement? From 50 feet away, there isn’t one.
What the public comment period should address
FMCSA wants comments on whether the proposed collection is necessary, whether the estimated burden is accurate, and ways to minimize that burden. The comment period closes 60 days after publication.
Here’s what we as an industry should actually tell them: The burden isn’t the 26 minutes per truck it takes to apply markings. The burden is a system that can’t distinguish between legitimate fleet operations and deliberate fraud. The burden is 153,000 annual violations that don’t even count toward CSA scores, giving carriers no safety incentive to comply. The burden is chameleon carriers causing three times the crashes while compliant operators spend money on new magnets every time they change lease agreements.
The marking requirements exist so investigators can identify who’s operating a vehicle. If those investigators can’t tell the difference between a compliant owner-operator and a chameleon carrier playing shell games with USDOT numbers, what exactly is the point?
Comments can be submitted at regulations.gov under Docket No. FMCSA-2025-1381. For further information, contact Stacy Ropp at the FMCSA Compliance Division.
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