Understanding ELD Exemptions: Do You Need Electronic Logging Devices?

ELD stands for Electronic Logging Device that is used by commercial motor vehicle (CMV) drivers to automatically track and log their driving time and Hours of Service (HOS) records, along with the vehicle engine, movement, and miles driven data. 

The Federal Motor Carrier Safety Administration (FMCSA) introduced the ELD mandate to improve highway safety and ensure accurate tracking of Hours of Service (HOS). By requiring most interstate commercial drivers to use electronic devices to automatically record driving time, the rule helps reduce fatigue-related crashes, minimize logbook errors, and strengthen compliance across the trucking industry.

However, not every carrier or driver is required to use an ELD. The regulation includes specific exemptions based on factors such as operational scope, vehicle age, and duty status. Understanding who qualifies for these ELD exemptions is essential for both fleet managers and owner-operators. Misinterpreting the rule can lead to costly violations, roadside penalties, or even drivers being placed out of service.

For fleets that do not qualify for an exemption, choosing the right FMCSA-registered ELD solution becomes equally important. And even for those who are exempt, adopting ELD technology may still offer operational benefits such as improved recordkeeping, efficiency, and oversight.

In this guide, we break down the key ELD mandate exemptions, explain who qualifies, and help you determine whether your fleet must comply — or can legally opt out.

What is the ELD mandate?

The Electronic Logging Device (ELD) mandate is a federal regulation issued by the Federal Motor Carrier Safety Administration (FMCSA) that requires most commercial drivers engaged in interstate commerce to use certified ELDs to track their hours-of-service (HOS). Effective since December 2017, the mandate aims to improve road safety by reducing driver fatigue, ensuring accurate recordkeeping, and minimizing errors or falsification associated with paper logs.

ELDs enforce core HOS rules designed to prevent driver fatigue:

• Maximum driving time: 11 hours following at least 10 consecutive hours off duty
• On-duty window: No driving after 14 consecutive hours on duty
• Mandatory break: 30-minute rest break after 8 hours of driving
• Off-duty recording: All off-duty periods must be clearly documented
• RODS (Records of Duty Status): Must accurately reflect all duty status changes, including driving, on-duty not driving, off-duty, and sleeper berth time

Who is affected by the ELD rule?

The ELD mandate applies to most interstate commercial drivers and their carriers in the United States. Specifically, it covers:

• Commercial trucks with a gross vehicle weight rating (GVWR) of over 10,000 pounds (4,536 kg).
• Passenger vehicles built or used in transporting more than eight passengers (including the driver) for pay.
• Passenger vehicles designed or used to transport 16 or more passengers, including the driver, without pay.
• Vehicles carrying hazardous materials that require placards under federal regulations.

Drivers who operate exclusively within a single state (intrastate commerce) are generally not subject to the federal ELD rule, though some states may have their own electronic logging requirements.

What are FMCSA ELD exemptions?

The Federal Motor Carrier Safety Administration (FMCSA), a division of the United States Department of Transportation (DOT),  regulates commercial driver hours-of-service (HOS) and enforces the use of electronic logging devices (ELDs).

The FMCSA recognizes that not all commercial operations fit neatly under the standard ELD mandate. In certain qualifying situations, drivers and carriers may be allowed to operate without using an ELD. These allowances, known as FMCSA ELD exemptions or DOT ELD exemptions, apply only when drivers meet clearly defined regulatory criteria.

Carriers and drivers who qualify can use alternative methods—such as paper logs or time records—to document hours-of-service (HOS) while remaining fully compliant with federal regulations.

Who is exempt from the ELD rule?

While most commercial drivers must use electronic logging devices (ELDs), the FMCSA recognizes that certain operational realities and vehicle limitations make ELD use impractical. As a result, specific exemptions exist, allowing eligible drivers to maintain paper logs or timecards to demonstrate hours-of-service (HOS) compliance when requested.

Exemptions generally fall into two categories:

Vehicle-based exemptions – 

These relate to the truck or engine itself. For example, vehicles with engines manufactured before model year 2000 are often exempt because they lack the electronic control modules (ECMs) required for ELD integration. In some cases, vehicles may qualify based on their VIN or engine swap history, but fleets must retain documentation, such as engine build sheets or VIN records, to prove exemption status during inspections.

Driver-based exemptions – 

These are tied to the driver’s duties or operational patterns. Drivers may qualify if they:

• Operate within short-haul limits (typically a 150-air-mile radius) and return to their home terminal daily.
• Use paper logs for eight days or fewer within any 30 days.
• Transport vehicles are the commodity itself, such as in driveaway-towaway operations.
• Perform agricultural hauls during planting or harvesting seasons within defined distances.
• Work in certain industries with FMCSA-issued waivers, such as logging, construction, or specialized fleets like film production.
• Engage in oilfield operations under the oilfield hours-of-service exception.

Although these exemptions relieve drivers from using ELDs, all HOS rules still apply. Fleets should maintain accurate records, track exemption eligibility, and ensure proper documentation to support claims during inspections.

ELD exemption rules: Benefits & criteria

Common ELD exemptions

Below, we’ll outline the most common FMCSA ELD exemptions, including those frequently relevant to small fleets evaluating whether they need to invest in an ELD solution.

1. Pre-2000 engine exemption

Drivers operating trucks with engines manufactured before model year 2000 are exempt from using ELDs. These older engines lack the electronic control modules (ECMs) required for ELD integration. Key points:

• The exemption is tied to the engine’s model year, not the vehicle’s manufacturing year.
• If a pre-2000 engine is installed in a newer truck, the exemption remains valid; conversely, replacing an old engine with a post-2000 model removes the exemption.
• Fleets should maintain engine build sheets or VIN documentation to prove exemption status during inspections.
• Even when exempt, drivers must follow all applicable hours-of-service (HOS) rules and maintain records of duty status (RODS) using paper logs or timecards.

2. Short-haul and local driver exemption

Drivers who operate within a limited radius and return to their home terminal daily may qualify for short-haul exemptions. Requirements include:

• Operating within a 150-air-mile (≈172 road miles) radius.
• Completing all duties within 14 consecutive hours and returning to the starting location.
• Maintaining at least a 10-hour off-duty break between shifts.

Under this exemption, drivers can use paper logs instead of ELDs, but they must still comply with HOS limits. For CDL-exempt drivers operating under a 100-air-mile radius, the rules are slightly stricter: daily work must end within 12 hours, and driving is limited to 11 hours per day.

3. Eight-day paper log exemption

Drivers who record RODS on paper for eight days or fewer within any 30 days are exempt from using ELDs on those days. Key points:

• Once a driver logs RODS on a ninth day within the rolling 30-day window, they must switch to an ELD for the remainder of the period.
• Drivers must maintain accurate paper logs during exempt days, while fleets should track the number of days each driver operates under this exemption.

4. Driveaway-towaway operations exemption

Drivers transporting vehicles as the actual commodity—such as newly sold trucks, motorhomes, or RVs—are exempt from ELD requirements. Requirements include:

• At least one wheel of the transported vehicle must remain on the road surface.
• Standard HOS limits still apply, but drivers are not required to take the 30-minute rest break mandated for other commercial drivers.
• Proper documentation, such as trip paperwork or carrier notices identifying the load as driveaway-towaway, should be maintained for inspections.

5. Agricultural operations exemption

Certain agricultural hauls during planting and harvesting seasons qualify for ELD exemptions. Key criteria:

• Operations must occur within a specified radius (generally 150 air miles) and a seasonal timeframe.
• Exempt hauls include transporting farm supplies, livestock, or crops to and from farms.
• Drivers may use paper logs or, in some cases, no logs, but all HOS rules remain in effect.

6. Industry-specific and FMCSA waiver exemption

Some specialized industries receive limited ELD exemptions through formal FMCSA waivers. Examples include:

• Construction, logging, or glass-hauling operations.
• UPS drivers using portable ELDs for yard moves or off-vehicle work.
• Film and television production crews or rental fleet drivers.

Carriers must register with FMCSA, maintain exemption letters in vehicles, and monitor expiration dates to remain compliant.

7. Oilfield operations exemption

Drivers servicing oil and gas sites may qualify under the oilfield HOS exception, which accounts for irregular schedules, rig moves, and continuous site operations. Key points:

• The exemption is job-specific, not company-wide.
• Drivers may use a 24-hour restart instead of the standard 34-hour restart.
• HOS limits still apply, but ELD use is not required during qualifying oilfield activities.

Other important considerations

Glider kits

Fleets sometimes use glider kits, which combine a new cab and chassis with a previously used engine. Since ELD exemptions are based on the engine’s model year, a glider kit equipped with a pre-2000 engine retains its exemption status.

Small carriers

There is no exemption for fleet size under the ELD mandate. Whether a company operates a single truck or hundreds of vehicles, it must comply with the federal ELD requirements unless it qualifies for another specific exemption.

Canadian ELD mandate exemptions

For fleets based in Canada operating in the United States, compliance with Canadian ELD mandate exemptions is required. These exemptions largely align with FMCSA rules but may include additional requirements. Following both U.S. and Canadian regulations is crucial to avoid fines or operational penalties.

Special exemptions for Canada- and Mexico-domiciled drivers

Canadian and Mexican carriers operating in the U.S. may be exempt from ELD use if they operate on paper logs for eight days or fewer within any rolling 30-day period.

Eligibility:

• U.S.-based drivers logging more than eight days in a 30-day window must use an ELD.

Implications:

• Drivers staying under the eight-day limit can continue using paper logbooks or other approved methods to track their hours-of-service (HOS).
• This exemption provides flexibility for cross-border drivers who occasionally operate in the U.S.

How to qualify:

• Maintain accurate records of all duty status days.
• Monitor the rolling 30-day total to ensure the eight-day limit is not exceeded.
• If the limit is surpassed, drivers must transition to an ELD or meet the requirements of another applicable exemption.

This rule offers Canadian and Mexican drivers some operational flexibility when temporarily crossing into U.S. territory, provided they carefully track their hours and remain within the exemption limits.

Why do ELD exemptions exist?

ELD exemptions are designed to address operational and technical challenges where electronic logging is impractical or unnecessary. Here are the main reasons exemptions exist:

• Short-haul drivers: Drivers with predictable routes and schedules can reliably use timecards instead of an ELD.
• Older vehicles: Trucks with engines manufactured before 2000 often lack the electronic control modules (ECMs) required for ELD integration, and retrofitting can be costly.
• Agricultural operations: Seasonal hauls and short-distance farm transport require flexible recordkeeping that fits variable schedules.
• Operational practicality: Some business models do not require continuous electronic monitoring due to limited driving time or specific duty structures.

These exemptions ensure that drivers and fleets can operate safely and efficiently without unnecessary compliance burdens, while still adhering to federal HOS rules.

How to determine if you qualify for an ELD exemption?

Determining whether you or your fleet qualifies for an ELD exemption is straightforward if you follow these key steps:

1. Review your operations

Start by assessing the nature of your work:

• Are you a short-haul driver operating within a limited radius?
• Does your truck have an engine manufactured before 2000?
• Are you involved in driveaway-towaway operations where the vehicle itself is the cargo?

Answering these questions helps identify if you meet the core criteria for an exemption.

2. Evaluate your driving distance and hours

Measure your daily driving distance in air miles (either 100 or 150, depending on the exemption type). Review your driving and on-duty hours over the past 30 days to ensure they fall within short-haul or occasional driving limits.

3. Maintain supporting documentation

Keep records such as timecards, vehicle registrations, or agricultural haul logs. Proper documentation provides proof of exemption during inspections and helps avoid potential compliance issues.

4. Seek guidance if needed

If you are unsure about your eligibility, consult the FMCSA website or a compliance expert. Clarifying your exemption status ensures you remain within the regulations and avoid costly errors.

Practical considerations and recordkeeping for ELD exemptions

Even if a driver or vehicle qualifies for an ELD exemption, carriers are still responsible for maintaining accurate records to demonstrate compliance with FMCSA regulations. Exemption from ELD use does not remove the obligation to track hours-of-service (HOS). In many cases, drivers must rely on paper logs, timecards, or trip sheets to document their duty status.

Documentation requirements by exemption type

1. Short-haul drivers

• Time records verifying the driver remained within a 150-air-mile radius.
• Confirmation that the driver did not exceed 14 hours of on-duty time.
• Records showing the driver returned to the same start location each day.

2. Eight-day-in-30 rule

• A log tracking the number of days a driver uses paper records (RODS) within a rolling 30-day period.
• Documentation confirming the driver transitions to ELDs immediately upon exceeding the eight-day threshold.

3. Agricultural operations

• Details of the commodity being transported (e.g., livestock, feed, or farm equipment).
• Origin and destination points, including the farm or starting location.
• Distance traveled within the 150-air-mile limit.
• Applicable seasonal dates, if defined by the state.

4. Pre-2000 engine vehicles

• Proof of engine model year, such as a build sheet, VIN record, or maintenance log, confirming the engine was manufactured before 2000.

How to ensure compliance after claiming an ELD exemption?

Claiming an ELD exemption does not excuse drivers or fleets from following FMCSA regulations. Even when exempt from using an electronic logging device, drivers must adhere to all hours-of-service (HOS) rules, including:

• Maximum driving hours
• Mandatory rest and off-duty periods
• Proper recording of special duty categories, such as personal conveyance, yard moves, or driving in adverse conditions

These activities still require accurate documentation, whether maintained through paper logs, timecards, or other approved methods.

Exemptions are not automatic. Carriers must actively monitor driver schedules, routes, and duty status to ensure the conditions of the exemption are continually met. Many fleets choose to install ELDs on exempt vehicles regardless, as doing so simplifies oversight, reduces errors, and minimizes the risk of compliance violations.

Staying ahead in ELD compliance

Maintaining ELD compliance goes beyond simply knowing the rules—it requires understanding when exemptions apply, keeping accurate documentation, and regularly reviewing eligibility. While exemptions can reduce administrative burdens, they are conditional and subject to close inspection.

Fleet managers should view exemptions as temporary and evolving privileges. Staying informed about FMCSA updates, monitoring rule changes, and adapting fleet operations proactively will help ensure continued compliance, reduce the risk of fines or out-of-service orders, and safeguard overall fleet efficiency and safety.

By combining careful recordkeeping, internal audits, and ongoing education, carriers can confidently navigate ELD regulations while leveraging exemptions responsibly.

Frequently asked questions about ELD exemptions

1. Which trucks are exempt from ELD requirements?

Some trucks are not required to use electronic logging devices because of their specialized operations or the type of cargo they transport. Examples of ELD-exempt vehicles include:

• Emergency vehicles such as fire trucks and ambulances.
• Military vehicles used for defense or government purposes.
• Recreational vehicles (RVs) and mobile medical units.
• Tankers carrying hazardous materials like gasoline, oil, or propane that must have passed a federal inspection within the 30 days before operating on public roads or highways.

These exemptions recognize that certain vehicles have unique operational needs or safety considerations that make ELD use impractical. Even though these trucks are exempt, drivers must still comply with all applicable hours-of-service rules and maintain proper records when required.

2. Do you still need to keep paper logs if you are exempt?

Yes. Even if you qualify for an ELD exemption, you are still required to maintain paper logs or timecards while on duty. These written records serve as official proof that you are complying with FMCSA hours-of-service (HOS) regulations.

Paper logs are essential in several situations:

• They document compliance when a driver cannot use an ELD due to technical issues or other valid reasons.
• They provide evidence during roadside inspections, audits, or any inquiries by law enforcement, showing that you have not exceeded driving limits or skipped mandatory rest breaks.

3. Can local drivers be exempt from ELD requirements?

Yes, local drivers may qualify for an ELD exemption if their operations meet specific criteria. Typically, drivers who complete trips within a 150-air-mile radius and return to their starting location within 14 hours can operate without an ELD.

4. How do small companies qualify for an ELD exemption?

The FMCSA evaluates small companies for ELD exemptions based on factors such as fleet size and annual revenue. These exemptions are designed to help smaller carriers with limited resources meet compliance requirements more easily, reducing administrative and financial burdens while still adhering to HOS regulations.

5. What are the risks of misclassifying drivers as ELD-exempt?

Incorrectly labeling a driver or vehicle as ELD-exempt can lead to serious consequences. If a roadside inspection or FMCSA audit determines that a driver should have been using an ELD, carriers may face fines exceeding $1,000 per violation. In addition, drivers can be placed out of service (OOS) immediately, potentially disrupting deliveries and harming customer relationships.

Enforcement officers carefully verify exemption eligibility, examining timecards, trip records, engine documentation, and agricultural or operational details. Any discrepancies between your records and the claimed exemption can trigger additional scrutiny or penalties.

To minimize risk, carriers should treat exemptions as conditional privileges, not automatic rights. Maintain accurate, detailed records for every exempt driver, route, and vehicle, and store backups digitally whenever possible.