FMCSR 393.13(b) Q&A: Retroreflective Sheeting Citations

No, not typically. Across our inspection records, 393.13(b) citations resulted in out-of-service placement in only 1 case out of 256 total citations—a 0.4% OOS rate. This is significantly lower than the 31.4% average OOS rate across all FMCSR codes, making this one of the least-enforced violations in the vehicle maintenance category. You will almost certainly be allowed to continue operating.

It's rarely enforced. Our database shows 393.13(b) ranks #1142 out of 3,036 FMCSR codes by citation volume. For context, the similar lighting code 393.9(a) (inoperable required lamps) has 660,737 citations with a 15.4% OOS rate—far more common and more likely to result in roadside shutdown. The retroreflective sheeting requirement is largely a legacy rule for older vehicles, so modern enforcement is minimal.

1. Document the vehicle's manufacture date—this violation applies only to vehicles made before December 1993.
2. If your vehicle is pre-1993, schedule inspection of retroreflective sheeting or reflex reflective material on all required surfaces.
3. Request a copy of the inspection report to verify the specific location cited.
4. Contact your fleet or carrier safety manager to log the violation and ensure records are updated.
5. Have the repair completed and documented for your next roadside inspection.

No active enforcement in the last 90 days, and zero citations in the last 12 months, according to our 13 million inspection record database. The 256 all-time citations span many years. This suggests the violation is either rare (few pre-1993 vehicles still in regular operation) or de-prioritized by enforcement. If you're operating a newer vehicle, you won't encounter this citation.

Yes. FMCSA's DataQs (DataQuality System) allows you to contest violations within 90 days of citation. For 393.13(b), your contestation would likely focus on whether the vehicle actually meets the retroreflective material requirement for its manufacture year, or whether the cited surfaces were properly equipped. Document any repairs, manufacturer specs, or photos showing compliant sheeting. Submit evidence through the FMCSA DataQs portal with your USDOT number.

Across our records, TRANSPORTES 4 AMIGOS S DE RL DE CV (USDOT 3971467) has the most citations at 8. Several other carriers have 2–4 citations each. The pattern shows this violation is scattered across many small and medium carriers rather than concentrated in one fleet. If you drive for a carrier with no history of 393.13(b) citations, the likelihood of encountering this violation is very low.

Freightliner (FRHT) units account for 24 of the 256 all-time citations. International (INTL) follows with 13, and Peterbilt (PTRB) with 11. Volvo, Kenworth, and other manufacturers also appear in the citation data. The prevalence of older heavy-duty tractor makes suggests that pre-1993 vehicles still in operation are the primary citation targets.

While our data does not specify the exact CSA points assigned to 393.13(b), it falls under the Vehicle Maintenance BASIC category in the CSA system. Given its extremely low OOS rate (0.4%), the severity weight is likely minimal. Consult your carrier's safety manager or FMCSA's Safety Management Guidelines for the specific points, but expect this to be a lower-severity violation than equipment failures that result in frequent out-of-service orders.