Electronic logging devices have been mandatory for most commercial truck drivers since December 2019. The question is no longer whether your operation needs one. The real compliance work is in knowing whether your fleet is set up correctly and whether you understand the exemptions that still apply.
Who Must Use an ELD
Any CMV driver required to keep records of duty status under 49 CFR Part 395 must use an FMCSA-registered ELD. That covers interstate drivers operating commercial motor vehicles over 10,000 pounds GVWR. It also includes vehicles of any size transporting placardable quantities of hazardous materials, as well as certain passenger-carrying vehicles.
The device must appear on FMCSA’s official registered ELD list to be legal for compliance purposes. Not every product marketed as an ELD qualifies. Verify registration at fmcsa.dot.gov before purchasing.
Who Is Exempt
Several exemptions remain in effect. Drivers who use paper records of duty status for eight days or fewer in any 30-day rolling period are not required to use an ELD for those trips. Driveaway-towaway operations, where the vehicle being transported is the commodity rather than the carrier, are also exempt. Vehicles manufactured before model year 2000 do not require an ELD regardless of the type of operation.
Short-haul drivers who qualify under the 100 air-mile or 150 air-mile radius exceptions in 49 CFR 395.1(e) and do not need to maintain RODS are excluded as well.
If you are unsure whether your operation qualifies for an exemption, that is worth confirming before an enforcement officer does it for you.
Roadside Inspections and ELD Data Transfer
At a roadside inspection, drivers must produce ELD data covering the current 24-hour period and the previous seven days. Transfer options are electronic (telematics upload to the officer’s device) or local transfer via USB or Bluetooth. Officers may also request an on-screen display.
Drivers must know how to operate the transfer function. An inability to produce data is treated as a violation even if the device is working correctly. Our hours of service compliance services cover ELD requirements as part of a full HOS review for carriers who want to confirm their drivers are inspection-ready.
ELD Malfunctions
When an ELD malfunctions, the driver must note it in their records and switch to paper logs immediately. The carrier has eight days from the reported malfunction to repair or replace the device. Running paper logs beyond that window without a working ELD is a violation.
A malfunction does not excuse a driver from producing accurate HOS records. Paper logs submitted during a malfunction period must be complete and current.
Questions about ELD compliance or HOS recordkeeping? Contact us for a free initial consultation.
Updated: June 14, 2026