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ELD Exemptions

A cautious overview of ELD exemption concepts and why carriers should verify the current eCFR and FMCSA guidance.

Quick Answer

ELD exemptions include drivers using paper logs for no more than 8 days in a 30-day period (the short-term exception), driveaway-towaway operations where the driven vehicle is the commodity, and vehicles manufactured before model year 2000 — each exemption has specific conditions that must be checked against the current text of eCFR Part 395 and FMCSA guidance.

ELD and HOS topics should be read with the related driver, carrier, and rule-specific pages. ELD Guide, Hours of Service, ELD Malfunction.

Who This Applies To

  • Commercial motor vehicle drivers and motor carriers subject to FMCSA Hours of Service regulations and the ELD mandate under eCFR Part 395.
  • Safety managers and dispatchers building driver log review procedures, HOS compliance policies, and ELD malfunction response plans.
  • Carriers verifying which drivers or operations may qualify for ELD exemptions, short-haul exceptions, or agricultural HOS waivers.

What To Verify

  • Whether the specific driver, vehicle, and operation are subject to ELD requirements or qualify for an exemption — verify current exemption criteria against FMCSA guidance and eCFR Part 395.
  • That any ELD device in use is listed on FMCSA's registered compliant device list at eld.fmcsa.dot.gov — using an unregistered device does not satisfy the ELD mandate.
  • Current driving and on-duty time limits for property-carrying versus passenger-carrying operations, and whether the operation uses the 60-hour/7-day or 70-hour/8-day schedule.
  • Carrier recordkeeping and retention requirements for ELD data and supporting documents, and the required paper log backup supply for malfunction situations.

Step-by-Step Overview

  1. Confirm whether each driver and operation is subject to ELD requirements or qualifies for an exemption using FMCSA guidance and eCFR Part 395.
  2. Verify that all ELD devices in use are listed on FMCSA's registered device list and that drivers are trained on daily log review and certification.
  3. Establish a carrier policy for ELD malfunction response: paper log backup procedure, driver notification timeline, carrier notification to FMCSA if needed, and device repair or replacement timeline.
  4. Implement a regular driver log review process to identify HOS violations, unassigned driving events, or data diagnostic flags before they appear in roadside inspections.
  5. Retain ELD records and supporting documents for the required period and carry blank paper logs in every vehicle at all times.

Common Mistakes

  • Assuming a specific operation or driver is ELD-exempt without checking current FMCSA exemption criteria — exemptions have specific conditions that may not apply to all operations.
  • Using an ELD device not on FMCSA's registered device list — an unregistered device does not satisfy the federal ELD mandate regardless of how it functions.
  • Not stocking blank paper logs in every commercial vehicle — when an ELD malfunctions, the driver must switch to paper logs immediately and may be inspected before the ELD is repaired.
  • Failing to notify the motor carrier within 24 hours of an ELD malfunction as required — the carrier then has a limited window to repair or replace the device before enforcement action is possible.

Official Sources

Related Pages

ELD Guide

A source-backed educational guide to ELD basics, official registered-device checks, and HOS recordkeeping cautions.

Hours of Service Guide

A source-backed educational overview of HOS rules for trucking businesses with official FMCSA/eCFR verification.

ELD Malfunction Guide

ELD malfunction response steps for drivers and carriers, including paper logs, notification timing, repair windows, and records.

FAQ

Is the short-haul exemption the same as an ELD exemption?

The short-haul exception is an HOS exception that also removes the ELD requirement for qualifying drivers — but the conditions are specific: the driver must operate within a 150-air-mile radius, return to the reporting location each day, and meet daily on-duty time limits. Verify all current conditions with FMCSA and eCFR Part 395.

Can this page be used to plan dispatch decisions?

Use it to frame questions and identify records to check. Dispatch decisions should be made from the driver's current duty status, carrier policy, and the current FMCSA or eCFR rule text.

What records usually matter most during a log review?

Daily logs, ELD annotations, unassigned driving, supporting documents, malfunction notes, and any exception being claimed should line up before the log is certified.