ELD Mandate Compliance Guide

What Is the ELD Mandate?

The ELD mandate, which took full effect on December 16, 2019, requires most commercial motor vehicle (CMV) drivers to use certified Electronic Logging Devices to record their hours of service (HOS). The rule replaced paper logbooks and automatic on-board recording devices (AOBRDs) with standardized digital technology that automatically records driving time.

Who Must Use an ELD?

The ELD rule applies to most drivers who are currently required to maintain records of duty status (RODS). This includes:

• Interstate CMV drivers operating vehicles with a GVWR/GCWR over 10,001 pounds
• Drivers transporting hazardous materials in placardable quantities
• Drivers transporting 9 or more passengers (including the driver) for compensation, or 16+ passengers regardless of compensation

Exemptions

The following drivers are exempt from the ELD mandate:

• Drivers who use paper RODS for not more than 8 days during any 30-day period
• Drivers conducting driveaway-towaway operations where the vehicle being driven is the commodity
• Drivers of vehicles manufactured before model year 2000

ELD Technical Requirements

A compliant ELD must meet several technical specifications defined in 49 CFR Part 395, Subpart B:

• Automatic recording: The ELD must automatically record driving time when the vehicle is in motion. It connects to the vehicle's engine ECM to capture engine power status, vehicle motion, miles driven, and engine hours.
• Driver interface: Must allow the driver to log in and out, select duty status (Off Duty, Sleeper Berth, Driving, On Duty Not Driving), add annotations, and certify logs.
• Data transfer: Must support at least two methods of data transfer to inspectors—typically wireless (Bluetooth or email) and display on screen.
• Tamper resistance: The device must not allow alteration of original data. Edits create audit trails that are visible to inspectors.
• FMCSA registration: The ELD must appear on FMCSA's registered ELD list. Devices that have been revoked or are not registered are non-compliant.

Common ELD Violations

Inspectors check for ELD compliance during roadside inspections. Common violations include:

• No ELD when required (driver placed OOS)
• Using an unregistered or revoked ELD device
• ELD malfunction not reported or documented
• Failure to have ELD instruction sheet and user manual available
• Unable to present logs to inspector via required transfer methods
• Unassigned driving time on the ELD

You can search for ELD-related violations in our violations database.

ELD Malfunction Procedures

If your ELD malfunctions, you must:

1. Note the malfunction and notify your carrier within 24 hours
2. Reconstruct your RODS on paper or a backup device for the current 24-hour period and the previous 7 days
3. Continue to manually record RODS until the ELD is repaired or replaced
4. The carrier must correct the malfunction within 8 days of discovery

Tips for ELD Compliance

• Verify your ELD is on FMCSA's current registered device list
• Keep a supply of blank graph paper logs in the cab for malfunction situations
• Ensure all drivers are trained on your specific ELD system
• Regularly review unassigned driving time and resolve it promptly
• Keep the ELD instruction sheet and user manual in the cab at all times