Frequently Asked Questions
What information may be requested to support the exemption for drivers not required to use records of duty status (RODS) more than 8 days in any 30-day period?
If a motor carrier’s operation is exempt from the requirements of 395.8, is the motor carrier also exempt from the ELD rule?
Are Canada- and Mexico-domiciled drivers required to use electronic logging devices (ELDs) when they are operating in the United States?
Yes. Canada- and Mexico-domiciled drivers must comply with the Federal hours of service rules while operating in the United States. This includes using ELDs unless they qualify for one of the exceptions. A driver operating in multiple jurisdictions will be able to annotate the driver’s record of duty status on the ELD with information on periods of operation outside the United States.
How should an ELD record a driver’s hours of service when operating in another country such as Canada?
Can drivers operate commercial motor vehicles (CMVs) equipped with electronic logging devices (ELDs), if they are not required to use them due to an exception?
How can the model year of commercial motor vehicle (CMVs) be found to determine if the CMV was manufactured before 2000 for the exception related to these vehicles?
The model year (MY) information can be found in the following table below. The model year code is the 10th digit in the vehicle identification number (VIN). Note that the letters I, O and Q are not allowed in the VIN, and the letters U and Z, and the number 0 cannot be used in the year code.
|A =||1980||L =||1990||Y =||2000||A =||2010||L =||2020||Y =||2030|
|B =||1981||M =||1991||1 =||2001||B =||2011||M =||2021||1 =||2031|
|C =||1982||N =||1992||2 =||2002||C =||2012||N =||2022||2 =||2032|
|D =||1983||P =||1993||3 =||2003||D =||2013||P =||2023||3 =||2033|
|E =||1984||R =||1994||4 =||2004||E =||2014||R =||2024||4 =||2034|
|F =||1985||S =||1995||5 =||2005||F =||2015||S =||2025||5 =||2035|
|G =||1986||T =||1996||6 =||2006||G =||2016||T =||2026||6 =||2036|
|H =||1987||V =||1997||7 =||2007||H =||2017||V =||2027||7 =||2037|
|J =||1988||W =||1998||8 =||2008||J =||2018||W =||2028||8 =||2038|
|K =||1989||X =||1999||9 =||2009||K =||2019||X =||2029||9 =||2039|
If a commercial motor vehicle is equipped with a glider kit that is newer than model year 2000, but the connections and motor vehicle components (such as the engine) are older than model year 2000, is the vehicle exempt from the ELD rule?
No. ELD use is required for vehicles whose VINs reflects a model year of 2000 or newer. The ELD rule requires a reasonable proxy for this data if the engine control module (ECM) or ECM connectivity does not provide it. If the currently installed engine does not support an ECM to obtain or estimate the required vehicle parameters, then the operator must use an ELD that does not rely on ECM connectivity, provided that the accuracy requirements of the final rule are met. See Appendix A to Subpart B of Part 395 section 4.3.1 of the ELD rule for accuracy requirements.
Drivers who use the timecard exception are not required to keep records of duty status (RODS) or use ELDs. Additionally, the following drivers are not required to use ELDs; however, they are still bound by the RODS requirements in 49 CFR 395 and must prepare logs on paper, using an Automatic On-Board Recording Device (AOBRD), or with a logging software program when required:
- Drivers who use paper RODS for not more than 8 days out of every 30-day period.
- Drivers who conduct drive-away-tow-away operations, where the vehicle being driven is the commodity being delivered.
- Drivers of vehicles manufactured before 2000.