FMCSA Confirms that ELDs Will Not be Required for Short-Term Rentals Begun Before April 20

TRALA received word from the Federal Motor Carrier Safety Administration (FMCSA) today confirming that short-term rental agreements signed on or before April 19 would be allowed to use paper logs rather than electronic logging devices (ELDs) until the end of the rental term.

The rental agreement must be 30 days or less and may not be "stacked" with future rental agreements.  What this means for example, is that if a rental agreement was signed for 30 days with a customer and that agreement began on April 15, the customer could continue to use paper logs until May 15 and then at that point would have to move to ELDs if the rental agreement were to be extended or a new rental agreement were to be entered into.

The TRALA waiver of three months granted by the FMCSA expires at the end of today, April 19 so any rental agreements that are more than 8 days in length that are signed starting tomorrow, on April 20 would NOT be allowed to use paper logs, but instead an ELD would be required unless the customer were to fall under another existing exemption.  Those exemptions would include the 100 air-mile radius exemption for CDL drivers, the 150 air-mile radius exemption for non-CDL drivers or the exemption that allows drivers that only exceed their 100 or 150 air mile exemption 8 or fewer days per any 30 day interval.  Lastly, any rental agreement of 8 days or less is exempt from the ELD mandate until December, 2022.

If you have any questions about this, please contact Jake Jacoby at or by calling (703) 299-9120.