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Who needs to use ELDs?
  • Most interstate CMV drives who are subject to the logging requirement must use ELDs.
  • Many intrastate drivers of CMVs also need ELDs but the specific requirements vary somewhat from state to state.
  • Just because an individual driver needs an ELD does not mean all drivers or all vehicles at that motor carrier must use ELDs.

Interstate commercial motor vehicle (CMV) drivers who are subject to the log requirements in 395.8 must use electronic logging devices (ELDs) in place of any other logging methods, with the following exceptions:

  • Drivers who are required to use a standard grid-style log on no more than 8 days within any 30-consecutive-day period are exempt from ELDs and may instead use paper (or digital) logs when needed. This includes intermittent or occasional drivers, as well as drivers who occasionally are unable to comply with the short-haul exception in 395.1(e) and who do not need logs more than 8 days out of 30. Once such a driver needs to use a regular log on 9 or more days within any 30-day period, the driver must switch to an ELD.
  • Drivers operating in a “driveaway-towaway operation” as defined in 390.5 in which the vehicle being driven is part of the shipment being delivered are exempt from ELDs. Those transporting motor homes or recreational vehicle trailers in a driveaway-towaway capacity are also exempt.
  • Drivers of vehicles manufactured before model year 2000 — when engine control modules (ECMs) were not required — are exempt from ELDs while operating such vehicles. The model year is identified by the 10th position in the vehicle identification number (VIN) as shown on the vehicle’s registration. In cases where the engine is older than model year 2000 but the vehicle is registered as being from model year 2000 or newer, such as with a glider kit, the engine model year is used to determine compliance and an ELD is not required. Motor carriers are allowed but not required to equip these older vehicles with ELDs.
  • Trucks that are rented for a term of eight days or less are exempt from needing an ELD, but the driver must carry copies of his or her logs, a copy of the rental agreement, and a copy of the Federal Register notice issued September 12, 2022, available upon request.
  • Drivers providing transportation to or from a theatrical or television motion picture production site can use paper logs under the terms of an exemption in effect until January 19, 2023. Drivers using the exemption must carry a copy of the Federal Register notice (or equivalent) published on January 19, 2018.
  • Drivers transporting livestock (as defined in 395.2) or insects are exempt from needing ELDs based on current Federal Motor Carrier Safety Administration policy and statutory requirements.

Many in-state-only (intrastate) drivers also need ELDs but the specific requirements and exemptions vary somewhat from state to state.

Note that the ELD standards apply to individual drivers and motor carriers. Just because an individual driver needs an ELD does not mean all drivers or all vehicles at that motor carrier must use ELDs. Some drivers for a particular company may always need ELDs, others may only need ELDs occasionally (when they cross the 8-times-per-30-days threshold), while others may be exempt. Also, just because a vehicle is equipped with an ELD does not mean that all drivers of that vehicle must use the ELD.