Which ELD exemption applies to my trucks?

Chapter 01

Which ELD exemptions are there, and which one fits each truck?

There are two kinds. The first kind frees a driver from logs altogether: the two short haul exceptions for local work, and the farm exemption at planting and harvest time. The second kind keeps the log but lets it be on paper instead of an ELD. That covers a driver who needs a log on 8 days or fewer in any 30. It also covers a truck built before model year 2000, driveaway work and a short truck rental. Every other driver keeps his log on an ELD (the log rule).

Here is how that looks in real life. Say you run four trucks out of one yard. Truck 1 is a dump truck. Its driver holds a CDL, hauls gravel to job sites up to 60 miles away, and is home most evenings. Truck 2 is a box truck light enough that its driver needs no CDL. It delivers building supplies around town. Truck 3 is a 2021 tractor on long runs through three States. Truck 4 is an old tractor you use for regional loads when work is heavy. It is October 2026, and you want to know which trucks really need an ELD.

Start with the rule for everyone. The federal rules on this page cover trucks in interstate commerce (the scope rule). For a truck that works only inside one State, ask your State which rules apply. Under the federal rules, you must make each driver record his duty status for every 24 hours. For most carriers that means an ELD, the electronic logging device that records driving time on its own (the log rule). The exemptions are the ways out. Owners often ask for a list of ELD exempt trucks. The honest answer is that most exemptions follow the work, not the truck.

Trucks 1 and 2 come home every night, so they may fit the short haul exception. It frees a driver from logs on days he works within 150 air miles of where he reports for work. He must also be back and released within 14 hours, with 10 hours off between shifts. You keep a time record for him instead (the short haul rule). Truck 2 has a second version, because its driver needs no CDL. The next section explains both versions in full.

Truck 3 qualifies for none of these exemptions. It runs long, so its driver keeps a log every day, and the log is on the ELD. That holds even if you drive truck 3 yourself. When the carrier is also a driver, the driver rules bind it too (the rule on the carrier’s duty). An owner-operator gets the same exemptions as anyone else, and no others.

Truck 4 is different. Its registration shows a VIN for model year 1998. The rules allow paper logs in a truck “manufactured before model year 2000”. They read the model year from the VIN, “as shown on the vehicle’s registration” (the log rule). So whoever drives truck 4 on a long run still keeps a log, but it can be on paper. This exemption goes with the truck, not with the driver. Paper logs are made in duplicate, on the grid the rules print, one for each 24 hours.

You may hear that a newer truck with an engine built before 2000 counts too. The rule text looks only at the model year the VIN shows on the registration. In 2022, FMCSA asked the public whether to change how the rule treats older and rebuilt engines (FMCSA’s 2022 notice). That wording has not changed since. FMCSA’s own ELD pages and answers to common questions blocked our checks, and we could not reach them through the web archive either. So go by the VIN, unless FMCSA has answered for your truck in writing.

Two other exceptions allowing paper logs rarely apply to a small fleet. The rules call them “driveaway-towaway” operations. One is when the vehicle being driven is itself part of the shipment being delivered. The other is when the vehicle being moved is a motor home or an RV trailer (the log rule).

Then there is the rental. Say truck 3 breaks down on October 5, and you rent a tractor for six days. FMCSA has excused trucks rented for 8 days or fewer from the ELD. It granted this to the truck rental companies’ association, called TRALA, and renewed it until October 12, 2027 (FMCSA’s rental exemption). The driver keeps a paper log on the days he needs one. He carries a copy of FMCSA’s notice and the rental agreement, which must name the parties, the truck and the rental dates. He has his logs for the current day and the 7 days before. You may not chain rentals. Trading one rental for another every 8 days, or renewing the same one, counts as a violation, with the penalties for having no ELD. If a crash happens while you are using this exemption, you must tell FMCSA within five business days. Before you rely on it, ask the rental company whether your rental falls under the TRALA exemption.

Many owners look for an ELD exemption form. For these exceptions there is none. You do not apply, and you do not file. A driver or a truck either fits on a given day or it does not, and your records show which. The only application is a different thing: asking FMCSA for a special exemption of your own. That takes a written request to FMCSA (how to apply). FMCSA publishes it in the Federal Register for public comment before it decides (what FMCSA does next). A grant lasts up to 5 years (FMCSA’s exemption rules). In February 2026, a truckers’ group asked FMCSA to let drivers choose paper logs instead of ELDs (the February 2026 notice). The Federal Register showed no decision on it as of September 22, 2026.

Here are the options side by side.

So at first sight, trucks 1 and 2 need no ELD, truck 3 needs one, and truck 4 can run on paper. The catch is in two words: each day. The next question is what keeps a local truck inside its exemption.

Chapter 02

What must a local truck do to stay free of logs?

A local driver is free of logs only on days that meet every condition. He works within 150 air miles of his normal work reporting location. The rule puts that at 172.6 ordinary miles, measured in a straight line. He is back there and released within 14 hours of reporting. He has at least 10 hours off before the next shift. And you keep a true time record of each day for 6 months (the short haul rule).

Your time record for truck 1’s driver shows three things for each day. They are the time he reported for duty, his total hours on duty and the time he was released (the short haul rule). A fourth applies to a driver you use for the first time, or only now and then. Add his total hours for the 7 days before. You get that from him as a signed statement, with the time he was last released from work (the log rule). The rule names what the record must show, not what it must look like. You can use a timesheet, a time clock or your dispatch software, as long as the record is accurate.

Air miles are measured in a straight line, not along the road. A job site 190 road miles away may still sit inside 150 air miles. Draw the circle once on a map around your yard, and give it to whoever books the loads. The 14 hours start when the driver reports for work, not when he starts driving. They run straight through, so loading, waiting and meal breaks all count. If he is released after 15 hours on a bad day, that day is not a short haul day.

The exception frees him from the log, not from the limits. Owners who look up the hours of service rules for short haul drivers often miss this. He still may not drive more than 11 hours. He still has the limit of 60 hours in 7 days. If you run trucks every day of the week, it is 70 hours in 8 days (the driving limits rule). What he skips is the 30 minute break after 8 hours of driving. That break does not apply to a driver who fits either short haul exception.

Truck 2’s driver has his own version, because his truck needs no CDL (the short haul rule). He too stays within 150 air miles. He comes back to his work reporting location at the end of each shift. But his day may run longer. On 5 days of any 7, he may not drive after the 14th hour on duty. On the other 2, the limit is the 16th hour. The same time record applies, kept for 6 months. A driver on this version cannot also use the other short haul rule, the sleeper berth rule or the 16 hour rule.

You may have heard of that 16 hour rule. It helps a driver who came back to his work location and was released there for his previous five shifts. Once in 6 days, he may be released up to 16 hours after coming on duty. A restart of 34 hours off lets him use it again sooner (the short haul rule). But it stretches only the workday limit. It does not stretch the log exception, which ends at 14 hours. So a 16 hour day is a log day.

Older advice still talks about 100 air miles and 12 hours. That was the rule until September 29, 2020. Then FMCSA widened the short haul exception to 150 air miles and a 14 hour day (FMCSA’s 2020 rule). If a checklist in your office says 100 miles, throw it out.

Now say an officer stops truck 1 on October 8 and writes up a missing log. That day, the driver was 40 miles from the yard and back in 10 hours. Your time record for that day is your proof. The rule puts that record with you, the carrier, so keep it where you can find it fast. You can ask for the violation to be removed through a DataQ challenge, FMCSA’s system for fixing inspection records.

Chapter 03

What happens on the days a local driver runs long?

On any day a local driver goes past 150 air miles or 14 hours, he loses the short haul exception for that day. He must keep a log for it. If he needs a log on 8 days or fewer in any 30, paper is enough. On the ninth log day in 30, the log must be on an ELD. FMCSA put it this way in 2020. Such drivers can run “for up to 8 days in any 30-consecutive day period without ELDs”, as long as they keep logs on paper (FMCSA’s 2020 rule).

Back to truck 1. In the second week of October, a builder wants gravel at a site 210 road miles away, 175 air miles from your yard. Your driver takes loads there on October 12 and October 14. On those two days he is outside the circle. He keeps a paper log for each day. That day he is not a short haul driver. So he may not drive past 8 hours of driving without a 30 minute break (the driving limits rule).

The paperwork changes on log days too. The paper log is made in duplicate, and he hands it in within 13 days (the log rule). You keep it for 6 months with the supporting documents for that day. Those are bills of lading, dispatch records, expense receipts, messages from your fleet system and pay records. You need to keep no more than eight for one driver’s day (the supporting documents rule). On short haul days, neither rule applies (the short haul rule).

One question remains unanswered. The rules have a driver carry his logs for the previous 7 days (the log rule). But on his short haul days before, he made no log. What he shows an officer for those days is covered on FMCSA’s web pages, which blocked our checks. Ask FMCSA or your ELD provider before his first long day.

Now the mixed case, one driver who does both. Truck 3’s driver takes a week off, and truck 1’s driver covers his long run from October 19 to 23. Truck 3 has an ELD, so he logs on it. Those five days are log days too, and they count toward the same limit of eight.

A shared ELD must know who is driving. You give each driver his own ELD account. It carries his name and license number as they appear on his license. Its username may not be his license number or Social Security number (the ELD rules for carriers). So set up an account for your local driver before the day he may need one.

Use a rolling 30-day period for the count. On any day, look back 30 days and count his log days. By October 28 he has 8: October 12 and 14, the five days in truck 3, and one more long job on October 27. The next long job would be the ninth. From that day, his log must be on an ELD. FMCSA called the choice “strictly a business decision on the part of the carrier” in the same 2020 rule (FMCSA’s 2020 rule). You keep the long days rare, or you put an ELD in the truck. There is one more way. If he takes truck 4 on a long run, his log there can still be paper, because truck 4’s exemption goes with the truck.

So keep one simple sheet for each driver. Each day, mark it as a short haul day or a log day. Before you give a local driver a long load, count his log days in the last 30. At eight, the next long load goes to a truck with an ELD, to truck 4, or to a driver who has log days left within the limit.

When you do add an ELD, it must be one on FMCSA’s list of registered devices. Each truck with an ELD carries three things. The first is an instruction sheet on sending the logs to an officer. The second is an instruction sheet on what to do if the ELD breaks down. The third is blank paper logs for at least 8 days. We explain what to do when an ELD breaks down on the road in our guide to ELD malfunctions. You also keep a backup copy of the ELD records on a separate device for 6 months (the ELD rules for carriers). One thing is gone. Since July 22, 2026, the ELD’s user manual no longer has to be in the truck (the July 2026 change). Checklists written before then still list it.

Why all this counting? Because a driver who ran long without a log has no record at all for that day. In a new carrier’s safety audit, failing to make a driver keep a log is one of the 16 automatic failures. It fails you when it shows up in 51% or more of the records checked (FMCSA’s audit rules). Our guide to what can automatically fail a new entrant safety audit covers all 16. Logs and supporting documents are also on the list of documents the auditor asks for.

Chapter 04

Do farm loads at harvest time change the answer?

Yes, during the planting and harvesting periods each State sets. Then the federal hours rules do not apply to a driver hauling farm products to a place within 150 air miles of where they were loaded. That means no log, no ELD and no hour limits on those trips. Past 150 air miles, the hours rules apply until the truck is back inside the circle. Those hours need a log (the farm exemption rule, FMCSA’s 2018 guidance).

Say it is harvest time in your State. A farmer asks you to haul corn in truck 1 from his fields to a grain elevator 80 miles away. The rule covers farm products “from the source” to a place “within a 150 air-mile radius from the source” (the farm exemption rule). The corn qualifies. Farm products count if they are not processed: fresh crops, grain, feed, fiber and livestock. Grain that is only cleaned or bagged still counts. Canned, frozen or dried food does not. Plants, sod, flowers and Christmas trees count too (the definitions rule).

The dates come from your State, not from FMCSA. The rule says the periods are “as determined by each State” (the farm exemption rule). Get your State’s dates in writing and keep a copy with the loads. We did not check any State’s dates.

FMCSA’s guidance says the source is where the load goes onto the empty truck. It can be a storage place or an elevator, if the crop keeps its original form. If the driver picks up more corn on the way, the circle stays around the first pickup. The empty drive to the farm and the empty drive back are covered too, while inside the circle. The trip must carry nothing but farm products (FMCSA’s 2018 guidance). For livestock, the rule measures the 150 air miles from the animals’ final destination instead (the farm exemption rule).

Now the farmer wants a second load taken to a river terminal 200 air miles away. FMCSA’s 2018 guidance answers this. The exemption covers “the initial 150 air-miles from the source”. After that, the hours rules apply, and the driver “must record those hours” until he is back inside the circle (FMCSA’s 2018 guidance). So that day becomes a log day, and it counts toward his eight in 30. One caution: the guidance said it would expire on June 7, 2023. In a 2020 rule, FMCSA said again that time inside the 150 air miles “does not count against the limits on maximum driving” (FMCSA’s 2020 farm rule). Whether the guidance itself was renewed is explained on FMCSA’s website, which blocked our checks.

The rule asks for no time record on farm trips. Keep the bills of lading or scale tickets anyway. They show what was hauled, where it was loaded and when. Without them, a harvest day looks like a day with a missing log.

So here is where your four trucks end up. Truck 1 needs no log on short haul days and harvest trips inside the circle. It keeps a time record, and it needs an ELD once its driver’s log days pass eight in any 30. Truck 2 runs on its time record. Truck 3 keeps its ELD, and a short rental can run on paper. Truck 4 can keep its logs on paper on every long run. The real work is the daily count and the records behind it. For the whole audit, see our guide to the new entrant safety audit.

We can keep that daily count, the time records and the logs in order for your fleet: here is what it costs.