ELD requirements: does your truck need one?
Whether you need an ELD is settled before the first log: by the truck's weight rating, the trailer behind it, the passengers or hazmat it carries, and whether the freight moves in interstate commerce.
Written by Gabriel Gonzalez
The numbers that decide it
ELD requirements apply to a truck when it is a commercial motor vehicle in interstate commerce: rated or loaded at 10,001 pounds or more, alone or with its trailer, or carrying placarded hazmat or enough passengers. A CDL is not the trigger. Non-CDL short haul, pre-2000 trucks, and a few other cases skip the device.
The most expensive ELD question is the one you ask after you buy the truck. A pickup with a gooseneck, a box truck rated just under CDL weight, a cargo van: each one lands on a different side of the federal line, and the answer decides whether you budget for a device, logs, and the records behind them.
I have spent more than 22 years at Simplex, nearly 16 of them as COO, and I now lead revenue strategy. This guide works through the ELD requirements vehicle by vehicle, from the federal definitions, so you can price the compliance into the equipment decision.
The full briefing, read aloud
7 chapters. Select one to jump to it.
Generated with AI text-to-speech from this article's key insights, in order, rather than reading it word for word. Chapter times come from a transcript of the audio. The article itself was written and reviewed by Gabriel Gonzalez.
Key takeaways
The vehicle sets the rule, not the license
A non-CDL truck rated 10,001 pounds or more in interstate commerce falls under the hours-of-service and ELD rules.
The higher number counts
The test uses the weight rating or the actual weight, whichever is greater, so a light load doesn't take a heavy-rated truck out.
A trailer can turn a pickup into a CMV
Truck and trailer ratings add up. Unhitched, only the pickup's own rating counts.
Non-CDL short haul skips the log
Within 150 air miles, back to base each day, and inside the 14- and 16-hour limits, a non-CDL driver needs no log or ELD that day.
In-state work can still be interstate
A trip inside one state is interstate when the freight's journey began or ends outside it. Purely intrastate work follows state rules.
In this articleContents
What are the ELD requirements, and which vehicles do they cover?
The ELD requirements cover every motor carrier whose drivers must keep records of duty status, and that duty starts with the vehicle. Under 49 CFR 395.8, those carriers have had to install ELDs and require drivers to use them since December 18, 2017.
The vehicle test is the definition of a commercial motor vehicle in 49 CFR 390.5T: a vehicle used on a highway in interstate commerce to carry property or passengers that meets any one of these tests:
- Weight. A gross vehicle or combination weight rating, or an actual gross vehicle or combination weight, of 10,001 pounds or more, whichever is greater
- Passengers for pay. Designed or used to carry more than 8 passengers, including the driver, for compensation
- Passengers, not for pay. Designed or used to carry more than 15 passengers, including the driver
- Hazmat. Carrying hazardous materials in a quantity that requires placards, at any weight
Business use is enough; you don't have to haul for hire. A private motor carrier, one that moves its own goods or equipment by commercial motor vehicle, is a motor carrier under the same definitions. The federal rules exclude the occasional move of personal property by an individual, not for pay and not for a business (49 CFR 390.3T(f)).
How do you count 10,001 pounds on a hotshot or pickup with a trailer?
Count the combination, not the truck. Under 390.5T, the gross combination weight rating is the greater of the rating the manufacturer shows on the truck's federal certification label or the sum of the ratings or actual weights of the truck and everything it tows.
One exception matters to hotshot operators: the truck's own combination rating doesn't count when it isn't towing. Unhitched, the pickup's gross vehicle weight rating decides.
| Setup | Weight that counts | CMV in interstate commerce? |
|---|---|---|
| Pickup rated 9,800 lb, no trailer | 9,800 lb rating | No, unless it carries placarded hazmat |
| Same pickup towing a gooseneck rated 14,000 lb | At least 23,800 lb, or the label's combination rating if higher | Yes |
| Dually or cab-and-chassis rated 11,500 lb, no trailer | 11,500 lb rating | Yes |
| Box truck rated 26,000 lb, running empty | 26,000 lb rating | Yes, the rating counts even when empty |
| Cargo van rated 9,500 lb towing a trailer rated 3,000 lb | At least 12,500 lb | Yes, while it tows |
The same ratings decide the license. A combination of 26,001 pounds or more, towing a unit rated over 10,000 pounds, is a Group A vehicle that needs a Class A CDL (49 CFR 383.91). Our guide to CDL vs non-CDL requirements covers what else changes for the driver.
Do non-CDL drivers need an ELD?
Yes, when they drive a commercial motor vehicle in interstate commerce and must keep logs. The ELD rule follows the vehicle and the duty to log, not the license, so a non-CDL box truck or hotshot driver skips the device only through an exception.
The exception written for them is the non-CDL short-haul exception in 49 CFR 395.1(e)(2). A driver of a property-carrying vehicle that doesn't require a CDL needs no record of duty status on a day when they:
- Operate within 150 air miles of the normal work reporting location
- Return to that location at the end of each duty tour
- Don't drive after the 14th hour after coming on duty on 5 days of any 7 consecutive days, or after the 16th hour on the other 2
The carrier still keeps 6 months of time records for those drivers: when they reported for duty, their total hours on duty, and when they were released. A driver using this exception can't combine it with the CDL short-haul exception, the sleeper-berth options, or the 16-hour property-carrying exception.
A day outside those limits needs a log. When that happens on more than 8 days in any 30-day period, the driver needs an ELD. Our owner-operator ELD FAQ walks through that 8-day count and the CDL version of the short-haul exception.
Do intrastate trucks need an ELD?
Not under the federal rule, as long as the work is truly intrastate, and that is a narrower category than it sounds. Under 390.5T, interstate commerce includes a move between two places in one state when the freight's trip began or ends outside that state or outside the country.
So a truck that never leaves its home state can still be in interstate commerce. A load picked up at an in-state rail yard or port, on its way from another state or country, is one example.
Purely intrastate work follows your state's rules, which can set different weights. Texas, for example, applies its adopted federal safety rules to intrastate vehicles over 26,000 pounds (37 TAC 4.11). Our Texas ELD mandate guide covers when Texas requires the device and its intrastate hours.
Which covered vehicles can still run on paper logs?
A few, but these exceptions swap the device for paper logs; they don't lift the hours-of-service limits. Under 395.8(a)(1)(ii), a carrier may let a driver log by hand instead of on an ELD when the driver:
- Drives a vehicle manufactured before model year 2000, as shown by the VIN on its registration
- Drives in a driveaway-towaway operation where the vehicle driven is part of the shipment
- Delivers a motor home or RV trailer in a driveaway-towaway operation
- Needs a record of duty status on no more than 8 days in any 30-day period
FMCSA reads the driveaway-towaway exception narrowly. Its ELD FAQ says hauling a mobile or modular home doesn't qualify: the truck pulling it isn't part of the shipment, and the home isn't a motor home or RV trailer.
Some operations step outside Part 395 entirely while they qualify, and the ELD rule goes with it. Agricultural moves within 150 air miles of the source during the planting and harvesting periods each state sets are one example (395.1(k)); FMCSA's FAQ confirms that an operation exempt from 395.8 is exempt from the ELD rule. Rentals and older engines in newer trucks are covered in our ELD compliance guide and owner-operator FAQ.
What happens if a truck that needs an ELD runs without one?
The driver is cited and placed out of service for 10 hours, or 8 hours for a passenger carrier, under the CVSA out-of-service criteria, according to FMCSA's ELD FAQ. After that, the driver may finish the current trip on paper logs, carrying the inspection report and proof such as the bill of lading if stopped again.
The truck may then return empty to the principal place of business or home terminal. Dispatch it again without a compliant ELD and the out-of-service process starts over.
For a small operation, a 10-hour stop can cost a delivery appointment and the next load behind it. Settle the question when you spec the truck. If it is covered, choose a device from FMCSA's registered list; our guide to ELD certification shows how to check one before you buy.
How Simplex helps you match the truck to the rules
Before you buy or dispatch, we help you confirm which rules your equipment brings and set up the device and records that go with them.
ELD solutions
Our ELD services cover registered devices, driver accounts, and the records your operation has to keep.
Starting a hotshot or box truck business
Our trucking startup services take you from registration to your first load, with the safety program in place.
Frequently asked questions
Do I need an ELD if my truck is under 10,001 pounds?+
Does a hotshot truck need an ELD?+
Is a CDL required for the ELD rule to apply?+
Do intrastate truckers need an ELD?+
What happens if I'm stopped without a required ELD?+
Where this information comes from
The requirements below come from federal regulation, FMCSA guidance and its ELD FAQ, and the Texas Administrative Code, checked on October 19, 2026.
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1
eCFR — 49 CFR 390.5T
Commercial motor vehicle, gross combination weight rating, interstate commerce, and private motor carrier definitions.
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2
eCFR — 49 CFR 390.3T
The safety rules apply to interstate commerce; occasional personal-property moves are excluded.
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3
eCFR — 49 CFR 395.8
ELD requirement since December 18, 2017, and the paper-log exceptions.
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4
eCFR — 49 CFR 395.1
The non-CDL short-haul exception and the agricultural exemption.
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5
eCFR — 49 CFR 383.91
CDL vehicle groups, including the Group A combination threshold.
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6
FMCSA — ELD Frequently Asked Questions
Out-of-service procedure without a required ELD, mobile home transport, and operations exempt from 395.8.
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7
FMCSA — Hours of Service
Who must comply with the hours-of-service rules, by weight, passengers, and hazmat.
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8
Texas Administrative Code — 37 TAC 4.11 (Cornell LII text)
Texas applies its adopted federal rules to intrastate vehicles over 26,000 pounds.
Written by
Gabriel Gonzalez
Chief Revenue Officer, Simplex Group
Chief Revenue Officer at Simplex Group, with more than 22 years at the company, including nearly 16 years as Chief Operating Officer. His background combines revenue strategy with deep operational experience, giving him a strong perspective on how compliance, risk, permits, cash flow, and operational readiness affect a carrier's ability to grow profitably.
Published · Updated
Related articles and services
Price the ELD into the truck, not the ticket
The ELD answer is fixed the day you choose the equipment: its rating, the trailer behind it, and where the freight goes. Run those numbers then, and the device and logs become a line in the budget instead of a roadside surprise.
If you want a second look at your setup before you buy or dispatch, talk to our team.