The 6 ELD Exemptions: Do You Need Electronic Logging Devices?

No one wants to get hit with a fine or, worse, have a driver pulled out of service due to a misunderstood compliance rule. That’s why understanding the electronic logging device (ELD) mandate is critical.

Designed to improve road safety, the mandate requires most commercial drivers to use ELDs for tracking hours of service (HOS) to prevent fatigue-related accidents and ensure accurate recordkeeping. However, many fleet managers are unaware that not every vehicle or driver requires one.

In fact, six key ELD exemptions could save you thousands in equipment costs, avoid unnecessary hassle, and simplify operations if you qualify. In this guide, we break down each ELD exemption and explain who qualifies, what documentation is required, and how motor carriers can stay fully compliant while saving time and money.

Overview of ELD Requirements

Electronic logging devices (ELDs) are tamper-resistant systems that connect directly to a vehicle’s engine and automatically record driving time. Their core function is to ensure accurate tracking of HOS, helping enforce limits on how long a commercial driver can be behind the wheel.

Unlike paper logs, ELDs eliminate guesswork and reduce the risk of driver fatigue, one of the leading causes of highway accidents involving commercial vehicles.

Under the Federal Motor Carrier Safety Administration (FMCSA) rules, most interstate commercial drivers must use an ELD to log their HOS. The core HOS limits and rules include:

• Maximum driving time: 11 hours after 10 consecutive hours off duty
• On-duty window: No driving after 14 consecutive hours on duty
• Break requirement: 30-minute break after eight hours of driving
• Off-duty time: Must be clearly documented and recorded
• RODS (records of duty status): Must be accurately maintained and include all duty status changes—off duty, sleep, driving and on duty (not driving)

The 6 ELD Exemptions

Some drivers are exempt from using ELDs and, in those cases, paper logs or timecards must still be used to show compliance if requested. In general, though, most heavy-duty, interstate carriers still fall under the mandate.

Below are the six official exemptions that allow drivers to avoid ELD use under certain conditions, along with key requirements and documentation tips to ensure compliance:

1. Short‑haul timecard exception

Drivers who qualify under the short-haul exemption can avoid using ELDs as long as they operate within a 150-air-mile radius and stay under 14 hours on duty each day. Eligible drivers must also take a 10‑hour off‑duty break between shifts and return home within 14 hours.

Crucially, if a truck driver uses paper logbooks for eight days or fewer in any 30‑day period, they remain exempt from ELD requirements. Once they exceed the on-duty time limits (14 hours), cross the 150-air-mile radius or log a ninth day, the exemption ends for that day, and ELD compliance is required.

Employers must retain timecards for at least six months, detailing clock‑in/out times and cumulative hours for each driver. Misuse can lead to non‑compliance fines and out‑of‑service orders for drivers.

2. Drive‑away/tow‑away operations

When the vehicle being moved is the actual commodity, such as delivering a new van, RV or tractor, the driver is exempt from using an ELD. To qualify, at least one wheel of the vehicle must remain on the road surface during transport.

Truck drivers can drive up to 11 hours within a 14‑hour window and must still follow standard HOS rules for off-duty and rest periods. However, they aren’t required to take the 30‑minute rest break that typically applies to other commercial drivers.

Drivers should keep trip paperwork or carrier notices identifying the load as drive‑away/tow‑away to support exemption claims during enforcement checks. Note that towing multiple trailers doesn’t qualify unless all wheels are on the road and the entire assembly is considered the commodity.

3. Pre-2000 vehicle models

Commercial motor vehicles with an engine manufactured before the year 2000 and, therefore, lacking the necessary engine control module (ECM), are exempt from ELD use. In other words, the exemption is engine-based, not vehicle-based. That means if you swap out a post‑2000 engine into an older vehicle, it becomes subject to the mandate, and vice versa.

Those who qualify for this exemption must still follow HOS rules and keep RODS using paper logs or timecards. This is because RODS are the official records used to show that a driver is complying with HOS limits, even when an ELD isn’t required.

Verifying engine model years and retaining records, such as engine build sheets or vehicle identification number (VIN) documentation, that prove the exemption applies is also essential.

No further HOS relaxations are granted for pre‑2000 engines; all other rules, like rest breaks and duty limits, remain in effect.

4. Driving eight or fewer days in a 30‑day period

Drivers who are required to keep RODS on eight or fewer days within any rolling 30-day period are exempt from using an ELD. This exemption is meant for drivers who only occasionally take trips that require RODS, such as long-haul or non-short-haul routes.

Once a driver logs RODS on nine days or more in a 30-day window, they must start using an ELD on the ninth day and continue using it for the rest of the 30-day period.

During the days when they are required to keep RODS but are still under the eight-day limit, truck drivers can use paper logs to record their HOS. If they operate under a short-haul exemption on other days, they may not need to keep RODS at all; they just need employer-maintained time records (time cards).

Motor carriers are responsible for:

• Tracking how many days each driver logs RODS
• Keeping accurate paper records for those days
• Installing ELDs as soon as a driver exceeds the eight-day threshold

Failing to switch to ELDs on time can result in costly violations or drivers being placed out of service.

5. Agricultural transport exemption

Drivers hauling agricultural goods, like crops, livestock, or animal feed, within a 150‑air‑mile radius of the farm during planting or harvest seasons are exempt from ELD use. The exemption applies only within defined seasonal windows and a working radius. Selected state definitions also apply.

Drivers must return to the farm daily and may use paper logs or no logs during exempt operations. If they travel beyond the radius, operate off‑season or exceed the daily window, they must comply with HOS through ELD or paper logs.

While Congress provides statutory backing, carriers should document seasonal schedules and cargo types to support exemption claiming during inspections.

6. FMCSA‑granted sector‑level exemptions

Certain industry-wide exemptions have been granted through early FMCSA waivers for sectors such as the United Parcel Service (UPS), film and TV production crews, and short-term rental and leasing fleets.

These waivers are time-bound. For instance, UPS has a waiver through 2027 that allows drivers using portable ELDs to manually record duty status changes and yard moves without syncing to the engine, due to the impracticality of automatic logging during off-vehicle work.

To qualify, carriers must register their vehicles, drivers, and operations with FMCSA and keep exemption letters accessible in each vehicle. These exemptions often exclude carriers from ELD requirements, but full RODS and HOS rules still apply.

Carriers must monitor waiver expiration and reapply if needed. If the exemption ends, ELDs must be installed promptly, or operations may be out of compliance.

Practical Considerations and Recordkeeping

While ELD exemptions reduce the need for electronic logging, they don’t remove the responsibility to prove compliance. Carriers and drivers must maintain clear, verifiable documentation that supports their exempt status under FMCSA regulations. In many cases, paper logs, timecards or trip sheets are still required to ensure HOS rules are met.

Required Documentation for ELD Exemptions

Here’s what fleets need to document based on the exemption type:

Short-haul drivers

• Time records confirming the driver stayed within a 150-air-mile radius.
• The driver worked no more than 14 hours.
• The driver returned to the same location each day.

Eight-days-in-30 rule

• A running log of how many days each driver has used paper logs (RODS).
• Confirmation of immediate transition to ELDs upon logging duty status on the ninth day within the 30-day period.

Agricultural operations

• The commodity being hauled (e.g. livestock, feed).
• The farm or origin point and destination.
• Distance traveled within the 150-air-mile radius.
• Seasonal dates if defined by the state.

Pre-2000 engine vehicles

• Engine model year verification, such as a build sheet or maintenance record, showing the engine was manufactured before 2000.

Ensuring Compliance After Claiming an Exemption

Fleet managers and motor carriers must also understand that claiming an ELD exemption doesn’t override other FMCSA regulations. Even if a driver is exempt from using an ELD, they still have to follow all HOS regulations. This includes limits on driving hours, mandatory rest breaks and required off-duty time.

Certain activities, like personal conveyance, yard moves or driving in adverse conditions, must still be recorded accurately, whether done through paper logs or other methods. These special driving categories have specific rules that still apply, even if the driver isn’t using an ELD.

Exemptions also aren’t automatic. Carriers must closely monitor driver behavior, routes and duty status to make sure the exemption conditions are met. Many fleets choose to install ELDs on exempt vehicles anyway, just to simplify oversight and reduce the risk of violations.

Risks of Misclassification and Enforcement

Misclassifying a driver or vehicle as ELD-exempt can come with steep consequences. If a roadside inspection or audit finds that a driver should have been using an ELD but wasn’t, carriers may face fines of over $1,000 per violation. Worse, drivers can be placed out of service (OOS) on the spot, disrupting deliveries and damaging customer relationships.

Enforcement officers are trained to verify exemption eligibility. That means reviewing timecards, trip records, engine documentation and agricultural source details. If your records don’t align with the claimed exemption, your fleet could be flagged for further scrutiny.

To stay protected, motor carriers should treat exemptions like temporary privileges, not guarantees. Maintain detailed records for every exempt driver and route, and back them up digitally whenever possible.

Running periodic internal audits helps confirm compliance, catch issues early and ensure your team is always ready to prove eligibility in the event of a roadside inspection or FMCSA audit.

Best Practices for Fleet Managers

Effectively managing ELD exemptions requires proactive planning, policy enforcement and regular training. Below are key practices every fleet manager should follow to reduce compliance risks and improve operational efficiency.

Regularly re-evaluate exemption eligibility

Routes, schedules and vehicle usage often change, so exemption status can, too. A short-haul driver today may cross into long-haul territory next week. Review driving patterns, engine specs and duty status records at least monthly to ensure no one is operating under outdated assumptions.

Implement clear policies and documentation

Set up formal procedures for using exemptions. This includes daily timecard tracking for short-haul drivers, logs confirming ≤8 RODS days, and signed verification of pre-2000 engine models. Store all documentation digitally and make it accessible during audits or inspections.

Use ELDs even when not required

While exemptions may apply, outfitting all vehicles with ELDs simplifies compliance tracking. It reduces administrative guesswork, provides real-time fleet visibility and avoids penalties if a driver unintentionally exceeds exemption limits. Many fleets treat ELDs as a safety net.

Train drivers on exemption rules

Driver mistakes are a leading cause of ELD violations. Conduct onboarding sessions and regular refresher training to cover key requirements, such as returning to base daily, staying within 150 air miles and keeping accurate paper logs. Empower drivers with printed guides and checklists for daily use.

Know when you’re truly exempt

ELD exemptions can offer cost savings and operational flexibility, but only if you fully understand and document your eligibility. Misclassifying a driver or vehicle can lead to fines, audits, and being placed out of service.

While exemptions are valuable for certain operations, most fleets still benefit from using ELDs to streamline compliance, improve route tracking and gather performance insights. Even when not required, ELDs offer peace of mind and help avoid accidental violations.

If you’re unsure about your fleet’s exemption status, it’s wise to conduct a compliance review. Speak with a qualified HOS expert or contact your FMCSA representative to confirm requirements.

When it comes to safety and legality on the road, clarity is the best route forward.