On July 12, 2017, the FMCSA answered a question regarding the ELD rule.
Q – If the vehicle registration for a commercial motor vehicle reflects a model year of 2000 or newer, but the connections and motor vehicle components (such as the engine) are older than model year 2000, is the vehicle exempt from the ELD rule?
A – Yes. When a vehicle is registered, the model year should follow the criteria established by the National Highway Traffic Safety Administration (NHTSA). There may be instances where the model year reflected on the vehicle registration is not the same as the engine model year, most commonly when a vehicle is rebuilt using a “glider kit.” In this circumstance, an inspector/investigator should use the model year on the engine to determine if the driver is exempt from the ELD requirements. If the engine model year is older than 2000, the driver is not subject to the ELD rule. In instances in which the engine model year is 2000 or newer, and the vehicle registration reflects a model year older than 2000, the driver is subject to the ELD rule. While the driver is not required to possess documentation that confirms the vehicle engine model year. 49 CFR Part 379 Appendix A, requires motor carriers to maintain all documentation on motor and engine changes at the principle [sic] place of business. If a determination cannot be made at the roadside, Law Enforcement should refer the case for further investigation.
This guidance deviates from FMCSA’s previous guidance, which emphasized the model year as determined by the VIN on a truck’s chassis.
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