Who this is for: CDL drivers, owner-operators, fleet managers
ELD Exemptions — Who Does Not Need an Electronic Logging Device
Not all drivers subject to FMCSA hours of service rules must use an ELD. Several exemptions exist. The most commonly used is the 150 air-mile short-haul exemption. Drivers relying on an exemption must understand its specific conditions — failing to meet every condition on a given day means ELD rules apply that day.
Important Notice
Exemption conditions must be met on each individual day to apply. Verify current exemption rules at fmcsa.dot.gov — rules change and third-party summaries may be out of date.
Short-haul exemption (150 air-mile radius)
CDL drivers may use the short-haul exemption and are not required to keep RODS — or use an ELD — on days when all of these conditions are met: (1) the driver operates within a 150 air-mile radius of the normal work reporting location; (2) the driver returns to the reporting location within 14 consecutive hours of coming on duty; (3) the driver does not exceed 11 hours of driving; and (4) the driver's start time does not vary by more than 1 hour from the previous 5 days. The driver must still keep accurate time records showing arrival and departure times at each location. The 14-hour on-duty limit still applies even when ELD and RODS requirements are waived.
8-day exception (occasional RODS users)
Drivers who are required to keep RODS for 8 or fewer days in any 30-day period are not required to use an ELD. On the days they do keep RODS, they may use paper logs. This exception is practical for drivers who occasionally take long-haul trips but primarily operate locally. Carriers must track and be able to document that a driver does not exceed 8 RODS days per 30-day period.
Driveaway-towaway operations
Drivers engaged in driveaway-towaway operations — where the vehicle being driven is itself the commodity being delivered — are exempt from ELD requirements if the vehicle being transported is not equipped with an ELD. This is common for auto haulers delivering individual vehicles and operators delivering newly manufactured trucks. The exemption applies to the specific vehicles being driven, not to other operations the carrier performs.
Pre-model-year 2000 vehicles
Vehicles manufactured before model year 2000 are exempt from ELD requirements because their engines may not have the electronic control modules needed to interface with an ELD. Drivers operating a pre-2000 vehicle must still comply with HOS rules and keep paper RODS if required — they simply do not need an ELD to do so. The model year is based on the engine, not the vehicle body.
What exempted drivers must do instead
Drivers using the short-haul exemption must keep time records (start and end times at each location) but not full RODS graph grids. Drivers using the 8-day exception or operating pre-2000 vehicles and who must keep RODS on a given day must use paper RODS. Drivers on any ELD exemption must still comply with all applicable HOS limits — the exemption is only from the ELD device requirement.
Frequently Asked Questions
What if I only sometimes qualify for the short-haul exemption?
On days you qualify for the short-haul exemption, you do not need an ELD or RODS. On days you do not qualify — for example, if you travel more than 150 air miles from your reporting location or do not return within 14 hours — you must have an ELD and comply with full RODS requirements for that day.
Is the 150 air-mile the same as 150 regular miles?
No. An air mile (nautical mile) is approximately 1.15 statute (regular road) miles. A 150 air-mile radius is approximately 173 statute miles from the reporting location in a straight line. However, the calculation is based on straight-line distance, not road miles traveled.
Can a carrier opt out of ELD requirements for its drivers?
No. If a driver is required to maintain RODS and does not qualify for an exemption, both the driver and the carrier must comply with ELD requirements. A carrier cannot waive ELD rules for its drivers.