ELD Mandate — Electronic Logging Device Requirements

The Electronic Logging Device (ELD) mandate requires most commercial drivers to track their hours of service using a registered ELD rather than paper logs. The rule was phased in starting December 18, 2017, with full compliance required by December 16, 2019 (when AOBRD — Automatic On-Board Recording Device — grandfathering ended). ELDs automatically record driving time by connecting to the vehicle's engine, eliminating the ability to fudge paper logs. The ELD market has consolidated into a few major players: Samsara, Geotab, KeepTruckin (now Motive), Omnitracs, EROAD, and J.J. Keller — these account for over 70% of the ELD market. ELDs cost $200-$800 per device plus $25-$50/month per truck subscription.

All commercial drivers required to maintain RODS (Records of Duty Status) under HOS regulations. This includes interstate property-carrying drivers operating CMVs 10,001+ lb GVWR, passenger-carrying drivers in 9+ passenger vehicles, and hazmat placarded drivers. Drivers using the 150-air-mile short-haul exemption are NOT required to use ELDs (they keep time records instead). Drivers operating pre-2000 model year engines are exempt (the engine ECM connection requirement doesn't apply to older mechanical engines).

(1) Drivers operating in 8 days or fewer in any 30-day period (very limited operations). (2) Drivers using the 150-air-mile short-haul exemption (keep time records, not logs). (3) Drivers of vehicles model year 1999 or older (pre-2000 ECM-equipped vehicles exempt). (4) Drivers required to keep logs for fewer than 8 days in any 30-day period. (5) Drivers of certain agricultural vehicles within statutory exemptions. (6) Driveaway-towaway operations where the truck being delivered is the cargo (limited circumstances).

Operating without an ELD when required: out-of-service for 10 hours, citation, CSA points. Tampering with an ELD: federal violation, potential criminal charges, automatic CDL disqualification. Carrier failure to retain records: up to $1,366 per violation. Pattern of ELD violations: FMCSA compliance review, potential carrier out-of-service order.

(1) Choose an ELD vendor carefully — switching is painful. Samsara and Motive are the most-installed for fleets; Garmin eLog is popular for owner-operators; J.J. Keller offers strong compliance support. (2) Cheapest option is BYOD (bring-your-own-device) ELDs that use a tablet/phone — under $300 hardware, $25-40/month. (3) ELD problems on the road: keep paper logs as backup for 8 days minimum until repaired or replaced. (4) Always log Personal Conveyance correctly when moving the truck off-duty (to fuel, restaurant, home) — this is the most common compliance grey area. (5) Yard moves at the shipper/receiver count as on-duty not-driving, not driving — annotate properly.

2019-12-16: AOBRD (older grandfathered devices) no longer permitted — all CMVs must have FMCSA-registered ELDs. 2022: ELD malfunction reporting requirements clarified — drivers must report malfunctions within 24 hours and switch to paper logs until repaired. 2024: FMCSA continues to revoke ELD registrations from vendors that fail to maintain compliance — check FMCSA's revoked ELD list before purchasing.

FMCSA ELD List (online), ELD User Manual, paper backup logs (RODS — Records of Duty Status)