ELD Requirements: Who Needs One & Who's Exempt

Why the ELD Mandate Matters

The ELD mandate requires most commercial motor vehicle drivers to use electronic logging devices to record their hours of service.² The rule replaced paper logbooks with tamper-resistant electronic records, making it harder to falsify driving time and easier for enforcement to verify compliance.

For carriers who already followed HOS rules honestly, the mandate added a technology requirement but did not change operations. For the industry overall, ELDs reduced the ability to run beyond legal driving limits, tightened capacity, and fundamentally changed how trucking operations plan their days.

Understanding the mandate is not optional. ELD compliance is checked at every roadside inspection, reviewed during DOT audits, and factors into your CSA scores. Non-compliance puts your authority at risk.¹⁰

The Core Requirements

Who Must Use an ELD

Any driver of a commercial motor vehicle who is required to keep records of duty status (RODS) under 49 CFR Part 395 must use a registered ELD.⁵ In practice, this means almost every interstate CMV driver operating a vehicle with a gross vehicle weight rating over 10,001 pounds or transporting hazardous materials in quantities requiring placards.

What the ELD Must Do

A compliant ELD must meet the technical specifications in 49 CFR Part 395, Subpart B, Appendix A.¹ The key requirements:

Automatic recording. The ELD must automatically record driving time when the vehicle is in motion. The device connects to the engine's electronic control module and detects vehicle movement without requiring driver input.

Duty status tracking. The ELD records four duty statuses: off-duty, sleeper berth, driving, and on-duty not driving. Drivers must be able to switch between non-driving statuses manually.

Data integrity. Records cannot be altered without creating an audit trail. The original data is preserved even when edits are made. This prevents the kind of logbook falsification that was common with paper logs.

Data transfer. The device must support transferring data to law enforcement during inspections, either through a display screen, USB drive, Bluetooth, or email.

Data retention. ELD data must be retained for a minimum of 6 months and be available to the carrier and to enforcement upon request.⁹

The FMCSA Registered Device List

The FMCSA maintains a list of self-certified ELD devices at the agency's website.⁴ Only devices on this list satisfy the mandate. However, the FMCSA does not test or independently verify these devices. Self-certification means the manufacturer attests that the device meets the technical specifications. It does not guarantee quality, reliability, or accuracy.

This distinction matters because some registered devices have had compliance issues, data accuracy problems, or have gone out of business leaving users stranded. Choose an established ELD provider with a strong track record. See our ELD buying guide for detailed selection criteria and our Motive vs Samsara comparison for a head-to-head look at two leading platforms.

Exemptions from the ELD Mandate

Not every CMV driver needs an ELD. The following exemptions exist under the current regulations.

Short-Haul Exemption

Drivers who operate within 150 air miles of their normal work reporting location and return to that location every day are exempt from maintaining RODS, and therefore exempt from the ELD requirement.⁸ To qualify, the driver must also complete the shift within 14 hours. Short-haul drivers must still comply with driving limits and the 14-hour window.

If a short-haul driver exceeds the 150 air-mile radius or the 14-hour window on any day, they must keep RODS for that day and use an ELD if they exceed the exception for more than 8 days in a 30-day period.

8-Day Exception

Drivers who use paper logs for 8 or fewer days within any 30-day rolling period are not required to use an ELD.⁸ This applies to drivers who drive infrequently or who occasionally operate outside their short-haul radius.

Pre-2000 Model Year Vehicles

Drivers of vehicles manufactured before model year 2000 are exempt because older engines may lack the electronic control module interface that ELDs require.⁸ The model year refers to the engine, not the vehicle chassis.

Driveaway-Towaway Operations

When the vehicle being driven is the commodity being delivered (such as delivering a new truck from a factory to a dealer), the driver is exempt from the ELD requirement for that trip.

Agricultural Operations

Certain agricultural hauling within 150 air miles of the source during state-defined planting and harvesting seasons may be exempt. The specific exemption periods vary by state and commodity.

ELD Compliance During Inspections

Roadside inspections are where ELD compliance gets tested in real time. Knowing what to expect reduces stress and prevents violations.

What Officers Check

During an inspection, the officer will ask to see your ELD records for the current 24-hour period and the previous 7 consecutive days.⁷ They check for:

• Active, functioning ELD connected to the vehicle
• Accurate duty status matching the vehicle's current state (the truck should not show off-duty if you were just driving)
• Complete records for the required 8-day window
• Supporting documents that corroborate ELD entries (fuel receipts, bills of lading, toll receipts)
• No unidentified driving time that has not been assigned to a driver
• Proper annotations for any edits or unusual entries

Data Transfer Methods

You must be able to transfer your ELD data to the officer. Most ELDs support multiple transfer methods:

1. Screen display -- Officer views records directly on the ELD display
2. USB transfer -- Data exported to a USB drive the officer provides
3. Bluetooth/email -- Electronic transfer to the officer's system

Have all methods ready. If one fails, the officer will request another. Inability to present records is treated as a violation.

Common Inspection Violations

Form and manner violations. Records that are incomplete, improperly formatted, or lack required fields. Ensure your ELD is configured correctly with your carrier information, vehicle details, and driver identity.

Unidentified driving. Driving time recorded by the ELD that has not been claimed by any driver. This happens when a driver forgets to log in before moving the vehicle, or when a co-driver moves the truck without switching the active driver profile. Review and assign unidentified driving daily.

False log entries. Records that conflict with supporting evidence, such as showing off-duty time when fuel receipts show the truck was traveling. Honesty in logging is both a legal requirement and a practical necessity, since ELD data is difficult to falsify without detection.

ELD Malfunction Procedures

ELDs are electronic devices, and they occasionally fail. The FMCSA provides specific procedures for handling malfunctions that protect you from violations as long as you follow them.

Immediate Steps

When you discover your ELD is malfunctioning:

1. Note the malfunction on your ELD or in writing, including the date, time, and nature of the problem
2. Begin paper logs immediately -- carry blank RODS forms in your vehicle at all times
3. Notify your carrier within 24 hours of discovering the malfunction⁶
4. Continue operating using paper logs that comply with all HOS rules

The 8-Day Repair Window

You have 8 days from the date of the malfunction to get the ELD repaired, replaced, or serviced.⁶ During this period, paper logs are your legal backup. After 8 days, you must either have a functioning ELD or stop operating until the device is repaired.

Best Practices for Malfunctions

• Keep blank paper RODS forms in your truck at all times
• Know how to fill out paper logs correctly before you need them
• Carry a backup ELD if possible (some providers offer spare units)
• Document the malfunction with photos or screenshots if the device shows error messages
• Save a record of when you reported the malfunction to your carrier

Setting Up Your ELD for Compliance

Getting your ELD set up correctly from the start prevents compliance headaches later.

Required Configuration

Your ELD must be configured with:

• Carrier information: Legal business name and USDOT number
• Vehicle information: Vehicle identification number, license plate, and trailer number
• Driver profile: Name, driver license number, and CDL state
• Home terminal: Time zone and address of your home terminal
• Operating rules: Set to the correct HOS ruleset (property, passenger, or applicable exemption)

Daily Compliance Habits

Pre-trip. Verify your ELD is powered on, connected to the vehicle, and showing the correct driver profile. Check that yesterday's logs are accurate and complete.

During the day. Change duty status promptly when your activity changes. Do not let the ELD auto-record driving time when someone else is moving the truck. Add annotations for any unusual events.

End of day. Review the day's logs for accuracy. Assign any unidentified driving time. Certify your logs before going off-duty.

Weekly. Review the past 7 days for completeness. Check for unsigned or uncertified days. Verify supporting documents are accessible.

ELD Data and Your CSA Profile

ELD data feeds directly into your CSA scores.¹¹ HOS violations recorded during inspections are weighted by severity and recency in the HOS Compliance BASIC. Carriers with high HOS violation rates face:

• Warning letters from the FMCSA
• Targeted investigations and DOT audits
• Higher insurance premiums
• Restricted access to broker freight

Maintaining accurate, compliant ELD records is one of the most straightforward ways to keep your CSA profile clean. The technology does most of the work. Your job is to use it correctly.

For the complete picture of how ELD compliance fits into your broader regulatory obligations, see our FMCSA compliance guide. For the HOS rules that your ELD tracks, see our hours of service guide.

Compare ELD providers on our ELD comparison page to find the right device for your operation.