After almost two years since finalizing the Federal Motor Carrier Safety Administration’s (FMCSA) Electronic Logging Device (ELD) ruling and a deadline of less than five months to become fully compliant with the mandate, attention has turned to what exemptions might need to be understood and addressed. Owner-operators with trucks equipped with model year 1999 engines and older will not be subject to the electronic logging device mandate, regardless of the model year of the vehicle. However, if a vehicle’s model year is older than 2000, but the engine model year is newer than 2000, the driver is still required to adhere to the ELD mandate. FMCSA has further stated that drivers are not required to carry documentation in the vehicle that confirms their engine’s model year, but notes that federal regulations require motor carriers to keep all documentation on motor and engine changes “at the principal place of business.” FMCSA further states that during a roadside inspection, law enforcement should refer the case for further investigation if they can’t determine the model year of the engine. Previous guidance had emphasized the model year was determined by the VIN on a vehicle’s chassis. Last month, the FMCSA issued a 20-page Frequently Asked Questions report with supporting documents, to help carriers comply with the rulings for the Electronic Logging Device (ELD) mandate.

We will keep you informed of ELD mandate updates as they develop and invite you to check out our ELD webpage for more information.

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