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Over the years, there has been constant confusion as to what the requirements are for non-CDL commercial motor vehicle (CMV) drivers. With the changes in the proof of medical qualifications regulations that CDL drivers are going through this summer, this is likely to get worse.

What is a non-CDL CMV

A non-CDL CMV is a vehicle that meets the definition of a CMV in 390.5, but not the definition of a vehicle requiring a CDL found in 383.5. This includes a vehicle that is used in interstate commerce and:

• Has an actual weight or weight rating of 10,001 pounds or more, but that does not meet the definition of a CDL-required CMV, or
• Seats between 9 and 15 (including the driver) and the company is being compensated for providing the transportation, and
• That does not require placards.

Roadside inspections

During a roadside inspection, non-CDL and CDL-required drivers are required to produce all of the same credentials and documentation. For a non-CDL CMV driver this includes:

• A valid license that covers the vehicle being operated (391.11(b)(5)). When it comes to non-CDL licenses, this will be based on the licensing requirements in the state the driver is licensed in.
• A valid medical card (§391.41). A non-CDL driver’s medical information is not merged into their license (like a CDL driver’s is), so the driver must present a valid medical card.
• Hours-of-service records of duty status (395.8), or an explanation of what exemption is being used that allows the driver to operate without records of duty status in the vehicle (such as 395.1(e)(2)). These drivers are also required to present any supporting documents that are in their possession unless they are using the applicable 150-air mile short-haul exemption (395.1(e)(2) and 395.11).
• Hazardous materials shipping papers and emergency response information if they are transporting any hazardous materials that requires these to be carried (if the hazardous materials require placards, the driver must have a CDL).
• Proof of a valid periodic (normally annual) inspection (396.17).
• Vehicle credentials, including the vehicle registration and proof of insurance.

The change

The change that might cause additional confusion is that as of June 23, 2025, medical examiners are no longer required to provide a CDL driver with a copy of the medical card after a medical exam is passed. The process of getting the current medical information onto the driver’s motor vehicle record (MVR) will be automated, making the physical card unnecessary.

The new process for CDL drivers will involve these steps:

1. The examiner uploading the exam results to the National Registry of Certified Medical Examiners (NRCME),
2. The Federal Motor Carrier Safety Administration (FMCSA) providing the information directly to the driver’s licensing agency, and
3. The agency updating the driver’s MVR with the new medical certification information.

With the driver being removed from the process, there is no need to provide the driver with a medical card.

This change, however, does NOT impact non-CDL CMV drivers. These drivers will still need to get a copy of the medical card from the medical examiner and carry it with them. This has always been required and should be business as usual for non-CDL CMV drivers.

Company (carrier) requirements

At the company level, full driver qualification files (DQ files) will still be required for both CDL and non-CDL drivers (391.51). The proof of medical qualification in the DQ file for a non-CDL driver will continue to be a copy of a current medical card, and for a CDL driver a copy of an MVR showing the driver is medically qualified. What is changing as of June 23, 2025, is:

• The carrier will no longer be required to verify the medical examiner is on the NRCME when a CDL driver does a medical exam (this will still be required when a non-CDL CMV driver does a medical exam – see 391.51(b)(8)).
• The CDL driver providing a medical card as proof of being medically qualified, and the carrier using it as proof of medical qualifications for up to 15 days after the exam, goes away. The only proof that a CDL driver is medically qualified as of June 23, 2025, is the medical information on the driver’s MVR (391.51(b)(6)).

Key to Remember: For non-CDL CMV drivers, there are no changes when it comes to proof of medical qualification. The proof of medical qualification for a non-CDL driver (on the road and in the DQ file) will continue to be a copy of a current medical card.

A J. J. Keller analysis of enforcement data from 2021-2024 reveals the price you could pay for violations of the Federal Motor Carrier Safety Regulations.

Last year alone, motor carriers and other companies regulated by the Federal Motor Carrier Safety Administration (FMCSA) paid nearly $27.3 million in fines, averaging over $7,000 per company. These figures are up slightly from the $26.7 million in fines paid the prior year, at just under $7,000 per settlement.

The following table shows the average fine (civil penalty) that motor carriers paid for the top 15 most cited* violations found during FMCSA investigations and audits over the four-year span from 2021–2024, including the top penalty paid by any company.

*NOTE: The list is based on all cited violations that, individually, resulted in a fine after an audit. Other common violations are not included if they did not result in a monetary penalty.

If passed, a new bill introduced in Congress – the Modern, Clean, and Safe Trucks Act – will repeal the 12 percent federal excise tax on the purchase of new heavy trucks.

The tax began in 1917 to finance America’s involvement in Worl War I. Despite previous attempts to repeal or reduce the tax — most recently in 2021 — it’s been extended and increased multiple times since its inception. The tax is currently scheduled to terminate on October 1, 2028 (Title 26 U.S. Code, Chapter 31, Subchapter C).

According to supporters of the bill, the federal retail excise tax adds:

• $7,000 or more to the cost of new trailers,
• $20,000 or more for new clean diesel trucks, and
• As much as $50,000 to the next generation of trucks with advanced engine technologies.

Findings noted in the bill argue that:

• The tax discourages the replacement of older, less environmentally clean and less fuel economical vehicles; and
• Repealing the federal excise tax would result in the replacement of older internal combustion engine trucks with new heavy-duty trucks that employ the latest safety and environmental technologies.

Revenue from the tax is currently dedicated to the Highway Trust Fund.

Adequate truck parking is critical to the success of the transportation industry. But, with an estimated national average of just 1 truck parking spot available for every 11 truck drivers, research on how to expand such parking options at public rest stops has recently become a top priority.

Truck parking concerns have sparked attention at both state and federal levels, prompting the American Transportation Research Institute (ATRI) to release data in collaboration with the American Association of State Highway and Transportation Officials (AASHTO). The agencies’ joint research covers all 50 state Departments of Transportation, as well as Puerto Rico and Washington, D.C.

Due to significant compliance challenges, the Pipeline and Hazardous Materials Safety Administration (PHMSA) has issued temporary enforcement discretion for the HM-263 final rule. This rule requires rail companies to provide real-time train consist information, which is crucial for emergency responders and law enforcement. However, Class I railroads are struggling to meet the compliance deadline, leading PHMSA to extend the enforcement period by one year to June 24, 2026.

This extension addresses issues such as employee training, IT system updates, and physical infrastructure installation. By providing additional time, PHMSA is ensuring that railroads can fully implement the necessary measures to enhance emergency response and investigative efforts. This proactive approach helps maintain safety standards while accommodating the practical challenges faced by the railroads.