FMCSA ELD mandate · Hours of service
ELD mandate — one FMCSA-registered device, one annual refresh, and the §395.3 hours-of-service record on the truck.
Mileafi carries the ELD track for the 1–50 truck fleet. We watch the FMCSA device registry refresh, the §395.22 applicability threshold, the §395.3 hours-of-service integration, and the §395.30 edit-narrative surface — so a removed device or a missing annotation never lands an out-of-service citation against the carrier at the next roadside inspection.
What the ELD mandate requires
Four surfaces cover the ELD mandate for a 1–50 truck fleet.
None of these are optional. §395.22 sets applicability on the truck. The device must be self-certified and registered on the FMCSA list. The HOS limits sit on the device via §395.3. The retention cycle runs on §395.11 — 6 months on the device, 6 months on the carrier back-office.
ELD-001
Who must use an ELD
Commercial drivers operating CMVs over 10,001 lb GVW in interstate commerce more than 8 days in any 30-day period must run an ELD. Pre-2000 model-year grandfather, short-haul < 150 air-mile radius exemption, and the drive-away-tow-away exception carve the boundary. The trigger is the truck and the operating pattern, not the carrier — reference §390.5 for CMV definition and §395.1 for the 8-in-30 day count.
ELD-002
Self-certified and FMCSA-registered device
An ELD must be self-certified by the manufacturer and registered with FMCSA on the public device registry. The DOT-numbered carrier is the user; the provider is the vendor. A device appearing on the FMCSA registry today can be removed tomorrow — the surface to monitor is the registry, not the truck. An unregistered device is the violation even when the device is physically mounted and recording.
ELD-003
§395.3 hours-of-service integration
Eleven-hour driving limit, 14-hour on-duty window, 60/70-hour duty cycle in 7/8 consecutive days, 30-minute break after 8 hours, 10-hour consecutive off-duty reset. The ELD captures every duty-status change automatically; the HOS limits sit on the device, not in dispatch software. A dispatch tool that logs hours without an FMCSA-registered ELD underneath is not in compliance with §395.22.
ELD-004
Annual device-registration cycle and record retention
FMCSA publishes an annual device-list refresh; a removed device renders the carrier non-compliant on the next duty-status event. ELD records retained 6 months on the device and 6 months on the carrier back-office per §395.11(c). Roadside transfer via FMCSA web services or email — the inspector gets the file before the citation is written, so the retention surface is the surface that decides the outcome.
Track it on a deadline calendar
Push your ELD track onto Mileafi’s ELD track — once your USDOT number and the current FMCSA-registered device are seeded, the four surfaces above appear as a single track with an annual refresh alert, an applicability-trigger alert on every fleet change, and an edit-tracking surface for §395.30.
Common pitfalls
The three things that flip an ELD track out from under a small fleet.
Each of these is a chassis swap that breaks the grandfather, an edit without an annotated narrative, or a registry removal that lands without notice — and the consequence arrives at the next roadside inspection, not through an FMCSA docket nudge.
PITFALL-01
Grandfathered truck no longer grandfathered after a sale or chassis swap
The pre-2000 grandfather turns on the chassis model year, not on the operating date. A replacement truck of a different model year flips the ELD obligation on overnight with no FMCSA docket nudge — and the ELD obligation arrives before the title transfer paperwork clears. A fleet running pre-2000 trucks that adds one post-2000 truck carries the full ELD burden from that addition, not from the next annual cycle.
PITFALL-02
ELD record edited and §395.30 audit trail opened
§395.30 requires every ELD edit to be annotated by the carrier with a written narrative. A driver who edits a duty-status entry without the carrier-side narrative is the record the safety auditor opens first on a §395.30 review. Annotations are not optional and not retroactive — they sit on the file at the moment of the edit, and a missing annotation is a per-edit violation that stacks across the inspection window.
PITFALL-03
Device removed from the FMCSA registry mid-cycle
FMCSA removes non-conforming devices from the public registry without notice. A fleet that does not check the registry on an annual cadence is running an unlisted device, and the next roadside inspection cites the absence from the registry as the violation — not the absence of the device itself. The audit cadence on the ELD track is the registry refresh, not the in-cab firmware push.
FAQ
The questions ELD-mandate carriers raise before they wire in a device.
The ELD mandate is a layer over §395.3 hours of service — the device captures every duty-status change, but the limits sit on the truck. These are the five questions that come up most often on the ELD track, and the answers that decide whether a fleet clears the next roadside inspection without a citation.
Page URL: mileafi.com/eld-mandate
Ready when you are
Start with Mileafi’s ELD track.
Sign up, drop in your USDOT number and the FMCSA-registered device you run, and the matching ELD surfaces light up inside your account. The annual registry-refresh alert and the §395.22 applicability-trigger cadence are on by default; you can run the device yourself or hand the §395.30 edit narrative to dispatch — Mileafi gives you the inspection-ready packet either way.