In December 2015, the FMCSA announced the ELD mandate will be enforced starting in December 2017. Although the final ELD rule applies to most commercial motor vehicle (CMV) drivers, there are some exceptions.
Is Your Fleet Exempt from the ELD Rule?
Let’s find out.
The following are four exemptions to the ELD rule. If you qualify for any of these, you are exempt from using an ELD.
1. Pre-2000 Vehicles
If the manufacturing date is before the year 2000 (1999 or earlier), the CMV is exempt from using an ELD.
This 2000 cut off was put into place because most vehicles manufactured prior do not have an engine control module (ECM), which is needed for ELDs. For drivers wondering if one could switch out their engine to an older model, note that the 2000 threshold is based purely on the truck’s manufacturing date, not the engine’s. You can easily find the manufacturing date by using the last 4-digits of the VIN.
Update: Recently, the FMCSA has clarified that the pre-2000 vehicle exemption does not apply to the Vehicle Identification Number (VIN). Instead, it applies to the engine model year.
It means that vehicles with engines that are older than the model year 2000 are exempt from the ELD mandate, regardless of the vehicle registration date. Similarly, vehicles with engines model year of 2000 or later will need ELDs, despite being equipped in trucks with VINs older than 2000.
Further reading: The FMCSA Clarifies the Pre-2000 Model Year Exemption.
2. Driveway-Towaway Operations
If you are a towaway driver and delivering a CMV is part of the shipment, you don’t need to have an ELD. The towaway drivers who deliver a truck don’t actually own the vehicle, and thus are not mandated to install an ELD in it.
3. Drivers Who Don’t Maintain RODS
Drivers not required to maintain Record of Duty Status (RODS) do not need to have electronic logging devices.
This ELD rule exception includes drivers who use the 100 air-mile and 150 air-mile short-haul exceptions.
4. Drivers Who Maintain RODS for Less Than 8 Days
If a driver maintains Record of Duty Status (RODS) for less than 8 days in a 30-day rolling period, he or she doesn’t need an electronic logging device. For instance, drivers who use the short-haul exception sometimes drive outside of the exemption radius. According to the ELD mandate though, if they are logging for less than 8 days in a 30-day cycle, they are exempt from the ELD rule.
Said differently, if the driver breaks the short-haul exception less than 8 times in a 30-day cycle, they don’t need an ELD. If however the driver breaks this exception more than 8 times in a 30-day period, the driver will need an ELD for the remainder of that 30-day cycle.
Summary of ELD Exemptions
The ELD mandate applies to the majority of CMV drivers. This includes unique situations, such as agricultural carrying fleets, vehicles carrying livestock, and oil field drivers. However, the ELD rule doesn’t apply to:
- Pre-2000 vehicles
- Towaway drivers
- Drivers who don’t need to maintain RODS
- Drivers who maintain logs for less than 8 days in a 30-day cycle
Despite the fact that some drivers and vehicles don’t need ELDs, fleets are adopting ELDs because of their various benefits. ELDs are known to reduce operational costs, improve efficiency, and increase profits. Learn how BP Express, a 300-vehicle fleet based in Rockford, TN, used ELDs to streamline operations.
If your fleet falls into any of the above-mentioned four categories, you won’t need an ELD. However, despite the exemptions, many fleets and owner-operators still choose to install Electronic Logging Devices because of the various benefits these devices offer.
Call 844-325-9230 if you have any questions. Our 24/7 active customer support team is always available to help you.
Disclaimer: The information being presented in this article is intended for informational purposes only and does not constitute, and should not be relied upon as, legal or other professional advice. You should contact your attorney to obtain advice with respect to any particular legal matter. No reader, user, or browser of this site should act or refrain from acting on the basis of information on this site without first seeking legal advice from counsel in the relevant jurisdiction.