FMCSR 393.13D3: Rear Reflective Sheeting – Q&A

No. Across all 13 million+ inspections in our database, not a single truck has been placed out of service for this violation. Our records show 227 all-time citations for 393.13D3 with a 0.0% out-of-service rate—meaning inspectors document the finding but do not remove the vehicle from service. This contrasts sharply with the all-FMCSR average out-of-service rate of 31.4%, making this one of the least severe citation types you can receive.

Low urgency relative to other equipment defects, but repair is still required. Because the 0.0% out-of-service rate means you can continue operating, the citation does not trigger immediate downtime. However, missing or defective upper rear retroreflective sheeting on pre-1993 vehicles is a documented safety issue. In the last 90 days, we recorded 32 citations for this code. Plan repair within your next scheduled maintenance window—this is not a roadside emergency like a brake or lighting failure.

First, photograph the cited area and document the exact condition of your upper rear reflective material. Second, inspect for co-occurring defects: in our last 90 days of data, trucks cited for 393.13D3 frequently also had inoperable lamps (393.9), brake issues (393.45B2UV), or missing emergency equipment (393.95A). Third, schedule repair of the reflective sheeting and any flagged co-defects within 30 days. Fourth, request the inspection report from your dispatcher and file it with your maintenance records to establish compliance effort. Keep repair receipts for any DataQs challenge.

No, 393.13D3 is considerably less severe than similar violations. Our inspection records show the peer code 393.9 (Inoperable Required Lamp) has 660,737 citations with a 15.4% out-of-service rate, while 393.11 (Lighting Devices/Reflectors) has 179,734 citations at 1.8% OOS. By contrast, 393.13D3 has only 227 citations and a 0.0% OOS rate. Inspectors treat missing pre-1993 retroreflective material as a lower-priority defect than active lamp failures or modern reflector problems.

Texas dominates the citation pattern: across our last 180 days of records, Texas accounted for 68 of the top state citations for 393.13D3—by far the highest concentration. Iowa follows with 3 citations, and New Mexico with 2. All three states showed a 0.0% out-of-service rate. If you operate a pre-1993 vehicle in Texas, prioritize this compliance item during pre-trip inspections to reduce exposure.

Freightliners dominate the citation record: across all-time data, 67 citations involved FRHT (Freightliner) trucks, followed by Kenworth (KW) at 33 citations. Volvo, Utility, and International also appear in the top makes. This pattern likely reflects the prevalence of older Freightliners in fleets still operating pre-1993 equipment. If you drive or manage an older Freightliner, inspect your upper rear reflective sheeting regularly to avoid citation.

Yes. Our 12-month trend shows citations peaked in November 2025 with 17 citations and August 2025 with 16 citations, then dipped in April 2025 and September 2025 (4 and 8 citations respectively). The last 90 days recorded 32 total citations. This suggests late summer and fall months see increased enforcement, possibly driven by pre-winter safety sweeps or end-of-month inspection quotas. Schedule preventive repairs before August if you operate older vehicles.

Yes, you can submit a DataQs (Roadside Inspection Records) challenge if you have evidence the inspection finding was inaccurate or unsupported. Because 393.13D3 is an equipment inspection (visual check of physical material), the burden rests on your maintenance records and photographic evidence showing the sheeting was present and compliant at the time of inspection. Gather pre-inspection photos, maintenance receipts, and repair dates. The FMCSA reviews challenges within 30 days and can remove or modify findings. However, if the material was genuinely missing or defective, the citation is likely to stand.