A recent FMCSA (Federal Motor Carrier Safety Administration) publication indicates that the ELD (Electronic Logging Device) mandate exemption is now based on the engine model year rather than the VIN (Vehicle Identification Number).
CMVs (Commercial Motor Vehicles) that are equipped with engines with the model year 1999 (or older) are no longer subject to the ELD mandate, regardless of the truck’s model year. However, trucks that have engines with the model year 2000 (or newer) still fall under the jurisdiction of the ELD mandate, despite being equipped on trucks with VINs older than 2000.
This particular ELD exemption has been a matter of debate for quite some time. As the FMCSA wasn’t entirely clear about this exemption (until now), some believed that the exemption is based on the engine model year, while others believed it is related to the VIN. The FMCSA, on various occasions, also implied that the exemption is calculated on the basis of the Vehicle Identification Number (VIN) — not the engine model year.
However, now that the FMCSA has clarified what the exemption applies to, there is no confusion. The exemption is based on the engine year, not the VIN.
According to the FMCSA, the model year should be based on the criteria established by the NHTSA (National Highway Traffic Safety Administration).
This means that vehicles with connections and motor vehicle components (such as the engine) that are older than the model year 2000 are exempt from the ELD mandate regardless of the vehicle registration date.
The instances where the model year reflected by the vehicle registration differs from the engine model year is due to trucks often being built out of glider kits. In these cases, inspectors and investigators are expected to use the engine model year as a basis for determining if the driver is exempt from the ELD requirements.
In the recently updated FAQ posted on the FMCSA website, the agency notes that drivers are not required to carry documentation everywhere they go to confirm what their vehicle’s engine model year is.
However, as noted in Appendix A of 49 CFR Part 379, motor carriers are still required to maintain all necessary documentation on changes to motor and engine components at the location of the business.
During roadside inspections, FMCSA suggests the law enforcement officers to refer the case for further investigation if they can’t successfully determine the engine’s model year.
If you are still looking for an ELD provider who can help you transition to ELDs, then you can reach out to us.