A recently updated FMCSA (Federal Motor Carrier Safety Administration) FAQ reveals that one of the ELD mandate exemptions is now based on the model year of the engine instead of the Vehicle Identification Number (VIN).
As you must know that the ELD mandate has four major exemptions. As per these exemptions, you won’t need an electronic logging device if:
The last exemption was always a little ambiguous.
Some believed that the model year 2000 refers to the chassis/VIN, while others believed it refers to the model year of the engine.
The FMCSA also never really clarified its stance on this exemption, until now.
As per a recent update by the FMCSA, it has been confirmed that the exemption applies to vehicles that have a pre-2000 engine model.
In other words, CMVs are exempt from the ELD mandate if they are equipped with engines bearing the model year of either 1999 or older. This status applies to vehicles regardless of its chassis model year located in the VIN (Vehicle Identification Number).
However, CMVs that are equipped with engines with a model year of either 2000 or newer still belongs to the scope of the ELD mandate, despite them being installed on vehicles with VINs bearing the model year of either 1999 or older.
The FMCSA also said that that the model year should be based on the specifications imposed by the NHTSA (National Highway Traffic Safety Administration). Moreover, the agency also recommended law enforcement officers to refer the case for further investigation if they can’t determine the model year of the engine during roadside inspections.
Additionally, the FMCSA does not require drivers to carry documentation with them to prove and confirm what the engine model year of their vehicle is.
However, the motor carriers are still mandated to maintain all pertinent documents on any changes to their CMV’s motor and engine components and keep them there at the main location of their business (see 49 CFR Part 379, Appendix A).
Now that the FMCSA has clarified an ongoing confusion regarding the ELD mandate exemption, you can determine whether you need ELDs or not.
If you believe you are not exempt from the ELD mandate, you should act now instead of waiting for last-minute compliance — which can be dangerous.
Stay tuned for more trucking industry news and updates about the upcoming ELD mandate.