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How the NRII process works (and why delays happen)

Under the NRII, medical examiners must enter a driver’s exam result into the National Registry no later than the end of the next calendar day. The FMCSA then sends these results to the appropriate SDLA so the information can be posted to the CDL MVR.

The most frequent source of delays is data-entry errors in the examiner’s electronic medical card (MCSA5850). Mistakes in key identifying information — such as name, date of birth, CDL number, or state of licensure — prevent the SDLA from validating the submission. When this happens, examiners receive an email alert but must correct the error before the SDLA can receive and post the record.

The FMCSA recognized early that MVR update delays were widespread, which led to several waivers. The current waiver, effective January 11 through April 10, 2026, allows carriers and drivers to rely on paper medical cards for up to 60 days after the exam.

Best practices for drivers and carriers

Proactive steps can significantly reduce both delays and compliance disruptions. Consider implementing the following:

1. Schedule exams early.

Encourage drivers to complete their exams at least two weeks before their certification expires. Maintain internal reminders to ensure drivers promptly report exam results and share a copy of their medical card.

2. Verify license information at the end of the exam.

Ask drivers to confirm that their personal information — name, date of birth, CDL number, and licensing state — matches what appears on the medical examination report (MCSA5876). Incorrect CDL formatting continues to be one of the most common causes of the NRII upload failures.

3. Request and retain a paper medical card.

Even though examiners aren’t required to issue a paper medical card, the FMCSA recommends that they do so during the NRII transition. Drivers should receive a paper card as these are legal proof of certification for up to 60 days under the current waiver and help prevent them from being placed out of service. A copy should go in the driver qualification file to be replaced by the updated MVR within 60 days.

4. Check MVRs within 2–5 days after each exam.

Early monitoring helps identify issues while examiners may be more receptive and able to quickly correct errors.

How to troubleshoot delayed MVR updates

The FMCSA recommends following a structured, three step troubleshooting process:

Step 1: Contact the medical examiner.

Confirm that they addressed any National Registry validation errors and resubmitted the MCSA5850. This is the most common issue that’s easily resolved.

Step 2: Reach out to the SDLA’s CDL help desk.

If issues pop up, carriers and drivers should contact the CDL help desk, not the general help line. Ideally, the call should include both a knowledgeable carrier representative and the driver. Begin by explaining that the examiner has already corrected any errors. Then request that the SDLA’s medicalcertification team “pull” the record directly from the National Registry.

Step 3: Contact the FMCSA Registry Support team if needed.

If steps 1 and 2 don’t resolve the issue, carriers and drivers should contact the FMCSA Registry Support team:

Phone: (617) 4943003

Email: fmctechsup@dot.gov

If the problem still isn’t resolved, carriers and drivers should document the steps taken to show good-faith efforts were made. If the driver’s MVR doesn’t update within the waiver period, to reduce the risk of having a disqualified driver citation, carriers should consider removing them from CMV driving until the MVR updates.

Key to remember: When carriers and drivers proactively manage medical exam timing and closely track MVR updates, they are less likely to face disqualification surprises or other compliance issues.

Key provisions

Key provisions of the final rule include:

Strict Eligibility: To be eligible for a non-domiciled CDL, the driver must possess an unexpired foreign passport and hold one of the following non-immigrant statuses:

• H-2A (Temporary Agricultural Workers),
• H-2B (Temporary Non-Agricultural Workers), and
• E-2 (Treaty Investors).

Proof of Eligibility: Applicants must present an unexpired foreign passport and specific Form I-94 documentation to the state driver licensing agency (SDLA). Employment Authorization Documentation (EAD) will no longer be accepted as proof of eligibility.

Mandatory SAVE Verification: State driver licensing agencies must query the Systematic Alien Verification for Entitlements (SAVE) system to confirm every applicant's lawful immigration status.

Specific Validity Period: The validity period for a non-domiciled CDL may not exceed the expiration date of the “Admit Until Date” of the driver’s I-94 documentation or one year, whichever is sooner.

This rulemaking is effective March 16, 2026.

What this means for California/CARB

The California Air Resources Board (CARB) may continue state-level enforcement of CTC for all in-state, out-of-state, and foreign-registered vehicles. However, they cannot claim SIP credit for emissions reductions from vehicles not registered in California.

What this means for trucking companies

Trucks not registered in California may still be subject to California enforcement, but EPA will not enforce those requirements federally. California cannot use those inspections or emissions reductions for SIP compliance.

Compliance options for testing

To comply with CARB’s CTC requirements, trucking companies can choose from multiple emissions testing options. Those options include:

• A telematics-based approach: The telematics option is a “set-it-and-forget-it” onboard diagnostics (OBD) test option. With this option, once the telematics device is set up on the vehicle, required data is automatically submitted to CARB.
• Hiring a credentialed tester to perform compliance testing: There are more than 30,000 credentialed testers, 15,000 of which are for hire. The “Credentialed Tester List - CTC-VIS” website features real-time updates to the list.
• Checking out a testing device from specified locations: Anyone can become a credentialed tester by taking the Tester Training Course and passing the exam in the Clean Truck Check-Vehicle Inspection System (CTC-VIS). Fleets can then perform the testing in-house without the need to hire third-party testers.
• Permit option: Finally, for vehicles that rarely operate in California, the HD I/M Regulation includes a five-day pass provision that allows any vehicle in the fleet to be operated in California for up to five consecutive days once per year without meeting the requirements of the rule.

FAQ: Does this regulation apply to my truck or fleet?

CTC applies to almost all diesel, alternative fuel, and hybrid vehicles, with a gross vehicle weight rating over 14,000 pounds, operating on public roads and highways in California — even if they are not registered in California. This includes:

• Government vehicles;
• Motorcoaches;
• Transit, shuttle, and school buses;
• Hybrid vehicles;
• Commercial and personal use vehicles;
• California registered motorhomes; and
• Single-vehicle fleets.

Freight contractors and brokers must:

• Only contract with compliant vehicles or fleets, and
• Comply with the record keeping requirements.

Ports and railyards also have requirements regarding CTC compliance status of vehicles and access to their facility.

Key to remember: EPA’s recent action does not end California’s CTC program. CARB enforcement continues, and trucks operating in the state are still required to comply with all program requirements.

Major proposed changes

Below are the most notable updates hazmat professionals should prepare for.

• Incorporations by reference
  PHMSA proposes adopting updated editions of the ICAO Technical Instructions, IMDG Code, UN Model Regulations, Transport Canada TDG Regulations, and multiple ISO gas cylinder standards.
• Hazardous materials table (HMT) revisions
  The rule updates numerous entries, adding new proper shipping names, revising hazard classes, modifying packing groups, and removing outdated entries.
• Expanded limited quantity relief for compressed gases
  For highway, rail, and vessel transportation, limited quantity authorizations expand to 1000 mL (34 fl. oz.) for argon, carbon dioxide, helium, and nitrogen, reflecting incorporation from both international regulations and prior U.S. special permits.
• Sodium ion batteries
  Reflecting rapid commercialization of sodium‑ion technology, PHMSA proposes new HMT entries (UN3551, UN3552) with requirements modeled closely on those for lithium‑ion batteries. This includes packaging standards, special provisions, vessel‑stowage rules, and certain air‑transport limitations.
• TMAH reclassification
  Based on new incident and toxicity data for Tetramethylammonium hydroxide (TMAH), PHMSA proposes:
  • A new entry for ≥25 percent aqueous solutions (UN3560),
  • Reclassification of solids and stronger concentrations to Division 6.1 (toxic) with Class 8 subsidiary risk,
  • Concentration based proper shipping names, and
  • New special provisions clarifying appropriate descriptions and providing transition time for hazard communication updates.

• New formulations for organic peroxides
  Several new peroxide formulations are added to the Organic Peroxide Table, allowing them to move without prior approval, and new packaging options are authorized for specific formulations, which is consistent with UN changes.

• Fire suppressant dispersing devices
  Growing use in industries like energy storage, server rooms, and transport sectors has prompted new rules for fire suppressant dispersing devices, including:
  • New entries for UN0514 (1.4S) and UN3559 (Class 9),
  • New classification and packaging criteria in §173.169, and
  • Requirements for testing, activation safeguards, and performance limits (e.g., surface temperature <200°C when activated in packaging).

• Lithium & sodium ion batteries
  To address thermal runaway risks in lithium and sodium ion batteries, PHMSA proposes:
  • A 30 percent state of charge limit for certain lithium and sodium ion batteries transported by air, including those installed in vehicles,
  • Extended requirements for prototypes and low production run batteries, and
  • Enhanced emergency response information for UN3536, battery energy storage systems.

• Gallium in manufactured articles
  New entry UN3554 provides clarity for gallium bearing articles, recognizing gallium’s role as a mercury alternative. New packaging and exceptions mirror international requirements.

• Marine pollutants list additions
  To align with IMDG Code updates, PHMSA proposes adding the following substances to the list of marine pollutants:
  • Isopropenylbenzene,
  • 2-phenylpropene, and
  • Cobalt dihydroxide powder (>10 percent respirable particles).

International updates PHMSA declined to adopt

PHMSA rejected several proposed international changes, including:

• More stringent IMDG requirements for carbon/charcoal,
• New battery powered vehicle marking/labeling requirements, and
• Prohibitions on use of UN Test N.4 for carbon classification.

Submitting comments

Stakeholders may file comments by April 13, 2026, via:

• www.regulations.gov (Docket PHMSA 2023 0111)
• Fax: 202-493-2251
• Mail/hand delivery to DOT Docket Operations in Washington, DC

Key to remember: HM 215R harmonization rule aligns the HMR with international dangerous goods standards. Hazmat professionals should review the proposed rule and provide feedback before the comment window closes.