A recent FMCSA (Federal Motor Carrier Safety Administration) publication indicates that the ELD (Electronic Logging Device) mandate exemption is now based on the engine model year rather than the VIN (vehicle identification number).
CMVs (commercial motor vehicles) that are equipped with engines with the model year 1999 or older are no longer subject to the ELD mandate. Regardless of the vehicles’ model year. But vehicles that have engines with the model year 2000 or newer still fall under the jurisdiction of the ELD mandate, despite being equipped on trucks with VINs older than 2000.
This ELD exemption has been debated for a while. Until now, the FMCSA wasn’t entirely clear about this exemption. Some believed that the exemption is based on the engine model year. And others believed it is related to the VIN. And there were a few times when the FMCSA implied that the exemption is calculated on the basis of the Vehicle Identification Number (VIN) and not the engine model year.
But now the FMCSA has clarified what the exemption applies to. So there’s no confusion. The exemption is based on the engine year. It is not based on the VIN.
The FMCSA says that the model year should be based on the criteria established by the NHTSA (National Highway Traffic Safety Administration).
This means that vehicles with connections and motor vehicle components like the engine that are older than the model year 2000 are exempt from the ELD mandate. And that’s regardless of the vehicle registration date.
The model year on the vehicle registration would only differ from the engine model year if the vehicle was built out of glider kits. If that’s the case, inspectors and investigators use the engine model year to decide if the driver is exempt from the ELD requirements.
Additional information about the FMCSA pre-2000 exemption
The FMCSA recently posted an FAQ page on their website. In it, they say that drivers don’t have to carry documentation everywhere they go to confirm what their vehicle’s engine model year is.
But Appendix A of 49 CFR Part 379 still requires drivers to maintain all necessary documentation on changes to motor and engine components at the location of the business.
What about during roadside inspections? FMCSA suggests that law enforcement officers refer the case for further investigation if they can’t successfully determine the engine’s model year.
If you are still looking for an ELD provider who can help you transition to ELDs, reach out to Motive.
The Motive ELD is FMCSA-registered, feature-rich, and easy-to-use. To learn more about the Motive ELD solution, call 844-325-9230 or email firstname.lastname@example.org.