FMCSA ELD Exemptions Explained

While the ELD mandate is pretty much the standard for most commercial trucking, it’s definitely not a one-size-fits-all rule. For your fleet, getting a handle on the specific FMCSA ELD exemptions is key to running efficiently and avoiding costs you don’t need to pay.

These carve-outs exist for a reason—they acknowledge that not every trucking operation fits the same mold.

Why Do ELD Exemptions Exist?

The FMCSA rolled out the ELD rule to boost safety by making sure you accurately track your Hours of Service (HOS). Simple enough. But the agency also knew that forcing an ELD into every single commercial vehicle just wasn’t practical or even necessary in some cases.

The real reason for these exemptions is common sense: they apply to situations where the safety risks that ELDs are designed to prevent are either super low or already managed in other ways.

Think of e logs for trucks as a heavy-duty tool built to track long, complicated driving schedules. If you aren’t running those kinds of routes, strapping an ELD into your truck is like using a sledgehammer to hang a picture frame—it’s just overkill. The rules provide specific outs for fleets that are mostly local, don’t run long-haul very often, or use older trucks that just can’t support the tech.

What Drives the Need for Exemptions?

A few key factors are behind the logic of the exemptions, which let certain operations stick with paper logs or other time records instead of a full-blown electronic device.

• Limited Driving Time: A lot of the exemptions, especially the short-haul rules, are for when you stick to a pretty small geographic area and are home every night. Your schedules are way less complex, which means the need for constant electronic monitoring just isn’t there.
• Infrequent Long Hauls: Then you have the “8-in-30 Day” rule. This is a nod to the reality that some of your drivers only occasionally need to keep a full Record of Duty Status (RODS). It offers flexibility so you’re not forced to install an ELD for a trip that only happens once in a blue moon.
• Technological Incompatibility: Let’s face it, the oldest trucks on the road were built long before ELDs were even a thought. The pre-2000 engine exemption is a practical acknowledgment that these vehicles don’t have the Engine Control Modules (ECMs) needed to connect to an ELD. This is a very different beast from the older AOBRD technology; you can get the full scoop on the differences between AOBRD vs ELD systems in our detailed guide.

To help you figure out where you stand, here’s a quick overview of the most common exemptions.

Quick Guide to Common FMCSA ELD Exemptions

This table is just a starting point, but it covers the exemptions that apply to the vast majority of fleets.

Navigating the 8-in-30 Day Exemption

Of all the FMCSA ELD exemptions, the “8-in-30 Day” rule is one of the most practical, but it’s also one of the most misunderstood. It’s a lifesaver for fleets with mixed operations. Think about it: if your drivers are usually running short-haul but occasionally have to take a longer trip, this exemption is your best friend. It gives you the flexibility to use paper logs for those rare runs without needing to buy and install an ELD in every single truck.

Ever since the ELD mandate kicked off in December 2017, this rule has been a go-to for many carriers. The exemption is straightforward: you can use paper records of duty status (RODS) for no more than 8 days during any 30-day period. This lets you sidestep the mandatory ELD requirement. Industry insiders estimate that 5–10% of the nearly 4 million commercial drivers in the U.S. lean on this exemption each year. You can dig into the fine print on the official FMCSA exemptions and waivers page.

This flexibility is a game-changer for managing things like a seasonal spike in long-haul jobs. You can adapt on the fly without the big upfront cost and training headaches for a device that might just collect dust most of the year.

How to Calculate the 30-Day Rolling Period

Here’s where most folks get tripped up: the “30-day period.” This is not a calendar month. It’s a rolling 30-day window. To stay on the right side of the law, you have to look at today and the previous 29 days.

Picture it this way: on any given day, you need to prove you haven’t required a paper log on more than seven other days in the last 29. If today makes day number nine that you’ve needed a log within that window, you’ve hit the limit. An ELD is now mandatory.

The key is constant monitoring. This isn’t a “set it and forget it” rule. Your safety manager needs a reliable system to track each driver’s log usage to ensure you never accidentally exceed the 8-day limit.

This proactive approach is the only way to avoid a simple mistake that could blossom into a major violation. It’s a critical part of preventing Hours of Service violations and keeping those CSA scores down.

What Documentation Is Required

When you are running under this FMCSA ELD exemption, you absolutely must have the right paperwork ready for an inspection. An officer is going to want to see proof of compliance.

Here’s the must-have list for the cab:

• Paper Logs: A stack of blank paper log sheets—enough to cover the duty status for the entire trip.
• Supporting Documents: The usual suspects you’d need even with an ELD, like fuel receipts, bills of lading, and dispatch records.
• Previous 7 Days of Logs: You must have your completed paper logs for the current day and the prior seven consecutive days on hand and ready for inspection.

If you are using this exemption and get pulled over for a roadside check, you have to produce these records immediately. Failing to do so can land you a violation, even if you technically qualify for the exemption.

What Happens on the 9th Day

So, the inevitable happens. You hit your ninth day requiring a RODS within that 30-day window. What now? The rules are crystal clear: at that moment, you must switch to using a compliant ELD.

This can’t be a scramble. You can’t just tell your driver to fire up an ELD mid-trip. The device has to be installed, and you need to be fully trained on how to use it before you dispatch them on a trip that you know will push you over the 8-day limit. Being prepared for this switch is the difference between a compliant operation and one staring down fines and out-of-service orders.

Understanding Short-Haul FMCSA ELD Exemptions

Understanding the DOT Hours of Service for local drivers is critical for both local and regional fleets. The short-haul exemptions are probably the most important—and most used—of all the FMCSA ELD exemptions. The whole idea behind them is to give a break to you if you stay close to home base and don’t really need the minute-by-minute tracking of an Electronic Logging Device.

Sounds simple, right? Well, it can get confusing in a hurry, especially since there are different rules for CDL and non-CDL drivers.

If you operate within these very specific boundaries, you can sidestep the cost and headache of ELDs. But you can’t just ignore record-keeping altogether; you still have to maintain the right alternative records to stay compliant.

Check out this short video about the short haul exemption to learn more: 

The 100 vs. 150 Air-Mile Rule

Since the 2020 HOS update, the standard short-haul radius is 150 air-miles—not 100. There are two short-haul options, and they’re based on whether the vehicle requires a CDL, not on driver status alone.

Option 1: Standard Short-Haul Exception — §395.1(e)(1)

• Who it’s for: Most local operations (CDL or non-CDL drivers) where the carrier can keep simple time records instead of full logs.

• Radius: Operate within 150 air-miles of the normal work reporting location.

• Duty window: Up to 14 consecutive hours, starting from the first on-duty punch.

• Return requirement: Report to and be released from the same location each shift.

• Records required (no RODS/ELD if used correctly):

  • Driver’s start time, end time, and total hours worked each day

  • Keep these records for 6 months

• 16-hour option: Certain property-carrying drivers may use the once-in-6-days (or after a 34-hour restart) 16-hour day under §395.1(o).

Option 2: Non-CDL Short-Haul Exception — §395.1(e)(2)

• Who it’s for: Drivers operating CMVs that do not require a CDL.

• Radius: 150 air-miles from the normal reporting location.

• Return requirement: Report to and be released from the same location each day.

• Duty limits:

  • May not drive after the 14th hour on 5 days in any 7-day period, and

  • May not drive after the 16th hour on 2 days in that same 7-day period.

• Records required: Same simple time records (start, end, total hours) kept for 6 months.

• Not eligible for the §395.1(o) “once-in-6-days” 16-hour option (that one belongs to the standard §395.1(e)(1) path).

How the Two Options Compare (At a Glance)

ELDs, Breaks, and Paperwork: What Still Applies

• ELD/RODS: When you operate fully under either short-haul option, you generally don’t need an ELD or daily RODS; your time records satisfy the logging requirement.

• 30-Minute Break: The federal 30-minute break is required only after 8 hours of driving time. Short-haul drivers often don’t accumulate 8+ hours of driving in a shift, but if they do, they still must take a compliant 30-minute non-driving break.

• Record retention: Keep time records for 6 months (include driver name/ID, date, start time, end time, and total hours).

When the Short-Haul Cushion Disappears (and What To Do)

Short-haul is “all-or-nothing” for the day. If, at any point, the run no longer fits every requirement of the short-haul option you’re using (e.g., you exceed the radius, you won’t return to the same reporting location, or your duty window will go long), the exception no longer applies for that day and the driver must have a complete RODS for the entire day (ELD or paper, as applicable).

Practical tip: Have a written protocol and tools ready so drivers can immediately switch to full logging if a delay or dispatch change blows the short-haul conditions.

Common Tripwires (Teach These to Dispatch ASAP)

• Mixing up the rules: The standard and non-CDL short-haul options are different. Don’t apply the §395.1(e)(2) 14/16-hour pattern to a CDL vehicle day, and don’t apply §395.1(o) to a non-CDL short-haul day.

• Forgetting the return rule: If the driver won’t return to the same reporting location, that day is not short-haul.

• Assuming “local = no break”: If a short-haul driver actually logs 8+ hours of driving in a shift, the 30-minute break rule still applies.

• No time records: Short-haul isn’t a “no paperwork” pass. If you can’t produce the required time records, you’re exposed.

• Dispatch drift: A “quick extra run” that pushes the radius or duty window over the line can instantly turn a short-haul day into a logging day.

Quick Triage for Mixed Fleets (CDL + Non-CDL)

1. Identify the vehicle requirement first: Does today’s CMV require a CDL?

   • Yes: You’re likely using the standard §395.1(e)(1) short-haul rules (14-hour window, optional §395.1(o) 16-hour day once in 6 days/after a restart).

   • No: You may use the non-CDL §395.1(e)(2) rules (14 hours on 5 days, 16 hours on 2 days in any 7-day period).

2. Confirm the plan fits: Same start/end location, within 150 air-miles, and time-record workflow in place.

3. Set a fallback: If something jeopardizes short-haul mid-day, switch to full logs immediately.

Bottom line: The modern short-haul world is 150 air-miles. Choose the correct option based on whether the vehicle requires a CDL, keep airtight time records, train dispatch on the tripwires, and have a RODS fallback ready for days that go sideways.

What Is An Air-Mile?

Here’s a small detail that can trip up even seasoned pros: the “air-mile.” This isn’t the same as a regular mile on your odometer.

An air-mile, also known as a nautical mile, is a straight-line measurement. Think of it as “as the crow flies.” It completely ignores the actual roads you have to drive to get from point A to B.

Just for reference, one air-mile is about 1.15 statute (road) miles. That means a 150 air-mile radius is actually closer to 172.5 road miles. This distinction is huge. If you’re using Google Maps and road miles for your calculations, you could easily send a driver outside the exempt zone without even knowing it.

Always use a tool that calculates distance in air-miles when planning routes for your short-haul exempt drivers. Relying on your truck’s odometer or standard GPS mapping for this specific compliance check is a recipe for a violation.

Record-Keeping Requirements Instead of an ELD

Just because you can skip the ELD doesn’t mean you’re off the hook for paperwork. The FMCSA still requires you to keep specific time records for any driver using the short-haul exemption.

For each driver, every single day, you must record:

• Your start time.
• Your end time.
• The total number of hours you were on duty.

These records need to be kept at your main place of business for at least six months. They also have to be ready for inspection if a DOT officer ever asks to see them. For a deeper dive, you can learn more about managing the short haul exemption in our detailed guide.

When a Short-Haul Day Becomes a Long-Haul Day

So, what happens when a routine day goes off the rails? You are normally a short-haul pro but get a last-minute call that pushes you beyond your air-mile limit or past your 12 or 14-hour duty day.

When that happens, the exemption for that day is toast. You are now required to immediately fill out a full paper Record of Duty Status (RODS), or paper log, for the entire day.

This is exactly the kind of situation where the “8 days in any 30-day period” exemption comes in handy. It allows you to use a paper log for that one-off long day without needing a full-time ELD in the truck.

Engine and Towing Specific Exemptions

While most ELD exemptions revolve around your routes and how often you’re on the road, a couple of key FMCSA ELD exemptions are tied directly to the truck itself. These are definitely more niche, but they can be a huge relief if your operation fits the bill.

Let’s dig into two of the big ones that can save you from buying and installing an ELD: driveaway-towaway operations and trucks running with pre-2000 engines. The FMCSA gets that some vehicles are either the product being sold or are just too old to play nice with modern tech. Knowing these rules can save you a chunk of change on equipment you’re not legally required to have.

The Pre-2000 Engine Exemption

This one sounds simple, but there’s a critical detail that trips people up: the exemption is based on the engine’s model year, not the truck’s. If your truck’s engine was manufactured in 1999 or earlier, you’re exempt from the ELD mandate. Period.

It’s a practical rule. Most engines built before the year 2000 don’t have the Engine Control Module (ECM) that an ELD needs to plug into. No ECM, no ELD. Simple as that.

So, how do you prove your engine’s age when you’re pulled in for a roadside inspection?

• Engine Serial Number: This is your best bet. The serial number is the definitive proof and can be used to look up the engine’s exact model year.
• Vehicle Identification Number (VIN): Sometimes the truck’s VIN can be used to track down the original factory specs, including the engine’s model year.

Bottom line: you absolutely need to keep documentation proving the engine’s age in the truck at all times. If an officer can’t verify it on the spot, you could be looking at a violation.

What About Glider Kits and Rebuilt Engines?

Good question. The pre-2000 rule often brings up “glider kits”—where a new cab and chassis are built around an older powertrain. The FMCSA’s stance is crystal clear: the exemption follows the engine. If you drop a pre-2000 engine into a brand-new glider kit, that vehicle is still exempt from the ELD rule.

The same goes for rebuilt engines. As long as you can prove the original engine block is from a 1999 model year or older, the exemption still applies. Just make sure you keep all the paperwork on these engine swaps at your main office and have copies ready in the glove box.

Driveaway-Towaway Operations

This exemption is for a very specific line of work. A driveaway-towaway operation is when the truck you’re driving is the actual product being delivered. In this specific situation, it isn’t considered a commercial motor vehicle under the ELD rule.

The core idea is that you are transporting the vehicle as a commodity, not using it to haul a separate commodity. If the truck is empty and being delivered for sale, lease, or repair, you most likely qualify for this exemption.

Here are a few classic examples of what qualifies:

• Delivering a brand-new tractor from the factory floor to a dealership.
• Moving an empty chassis from one company terminal to another.
• Transporting a motorhome or RV for delivery to a customer.

Now, even if you fall under this exemption, you’re not totally off the hook for logging. If the trip is long enough to require logs, you still have to fill out a paper Record of Duty Status (RODS). This rule just means you don’t have to do it with an electronic device.

How to Request a Special Exemption from the FMCSA

What happens when your operation is so unique that none of the standard FMCSA ELD exemptions seem to apply? If you’re in a truly one-of-a-kind situation, the FMCSA has a formal process for requesting a temporary break from the ELD rule—or any other federal safety regulation, for that matter.

But let’s be clear: this isn’t some secret loophole. The bar for getting an approval is incredibly high. You have to build a rock-solid case proving your alternative method is at least as safe as following the original rule.

Building Your Case for an Exemption

To get the ball rolling, you’ll need to submit a formal application to the FMCSA. This isn’t like filling out a simple form; think of it more like preparing a legal argument. Your application must be detailed, persuasive, and, most importantly, backed by solid data.

Here’s what you’ll need to include:

1. A Clear Explanation: State exactly who you are, which specific regulation you want an exemption from (in this case, the ELD mandate), and how long you need it for (the maximum is five years).
2. A Safety-Equivalent Argument: This is the heart of your request. You have to prove how your proposed alternative will maintain or even improve safety compared to just using an ELD. You can’t just say it’s safer; you need data, operational models, and a compelling analysis to back it up.
3. Public Comment: Once you submit your application, it gets published in the Federal Register. This opens the door for the public to weigh in. Any strong opposition can make an already tough approval process even harder.

This entire process demands meticulous documentation. Any mistake or missing piece of information can lead to long delays or an outright denial. By the way, if you ever find inaccuracies in your safety records during this or any other process, knowing how to challenge incorrect data through the FMCSA’s DataQs system is a crucial skill.

Understanding the Odds of Success

It’s really important to set realistic expectations here. The chances of getting a case-by-case ELD exemption are slim. Between 2017 and 2023, the FMCSA granted fewer than 50 individual exemption requests related to ELD requirements—that averages out to just a handful each year.

The agency keeps a public database of these requests, and a quick look shows that most approvals are for very small, technical aspects of the rule, not a complete waiver. Despite these rare exceptions, enforcement data shows that well over 90% of U.S. interstate drivers now use FMCSA-registered ELDs, so compliance is the overwhelming norm. You can read more about current ELD compliance trends from the FMCSA on their site.

The FMCSA puts safety above everything else. If your request is based on saving money or making things more convenient—without an airtight safety case—it’s almost guaranteed to be denied. Your entire argument has to hinge on proving your way is just as safe, if not safer, than the regulation you’re trying to get around.

This path is reserved for truly exceptional circumstances, not for fleets just looking for an easier way to handle compliance. Before you even think about starting, carefully weigh the huge amount of time and resources this will take against the very slim odds of success.

Frequently Asked Questions About FMCSA ELD Exemptions

Let’s be honest, navigating the world of FMCSA ELD exemptions can feel like trying to read a map in the dark. To help cut through the noise, we’ve put together some quick, straightforward answers to the questions we hear most often from fleet owners and safety managers like you.

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