When Are Drivers Required to Start Using Electronic Logging Devices?

Most drivers of commercial motor vehicles will be required to install and use electronic logging devices (ELDs) by the compliance date of December 18, 2017, by which time a majority of trucking fleets will have this technology fully implemented. Using this technology, the FMCSA hopes there will be an increase in the efficiency and accuracy of tracking for all shipping operations.

However, there are a few exceptions to the rule, which are exempt from this rule until December 16, 2019. By that date, all commercial motor vehicle operations will need to make the switch to contemporary ELDs.

Grandfathered Automatic Onboard Recording Devices (AOBRDs)

The main cause for an exemption from the ELD rule is the use of a grandfathered automatic onboard recording devices (AOBRD). These devices can comply with the requirements of 49 CFR 395.15, but drivers must begin using contemporary ELDs by December 16, 2019. AOBRDs have been in use since 1988, but many vehicles still utilize them.


Another potential exemption from the ELD rule until 2019 is the use of Electronic Onboard Recorders (EOBRs). These devices are more recent than AOBRDs, becoming common in the early 2000s. The FMCSA referred to all electronic logging devices until the ELD replaced the term in 2012.

Other Exemptions

Three main criteria can provide exceptions to the ELD rule for CMV operators, including:

  • Drivers who use paper RODS for no more than 8 days within any 30-day period
  • Drivers operating vehicles manufactured prior to 2000
  • Drivers who conduct drive-away-tow-away operations, in which the vehicle is the commodity being delivered

Keep in mind that drivers using RODS don’t need to restrict the 8 days of use to a specific month. For example, using paper RODS is acceptable if used during any 8-day period starting on June 14 and ending on July 14.

Complying with the Final Rule

All commercial vehicle drivers and carriers are required to comply with the FMCSA’s final rule, regardless of which devices they use.

The requirements of the Final Rule are as follows:

  • Carriers and drivers currently using AOBRDs or EOBRs are required to make the transition to ELDs by the compliance date of December 16, 2019
  • Carriers and drivers not currently using EOBRs or AOBRDs must install ELD systems by December 18, 2017
  • Drivers must be able to log in to and select off-duty, on-duty, or on-duty but not driving options
  • The driver’s Record of Duty Status (RODS) needs to be clearly visible and readable at a glance
  • Tablets and smartphones are permitted for use in ELD systems as long as they meet FMCSA compliance standards

Regardless of the type of device you’re currently using to track hours of operation, you must be able to comply with this Final Rule. As long as you are able to meet the FMCSA’s specific requirements, you aren’t required to install an ELD until the final compliance dates, depending on the device you’re currently using.