ELD Mandate Short-Term Rental Clarification

The ELD mandate has caused an ongoing stir, not only among fleet companies and owner-operators, but in the world of truck rentals, too.

One reason: the target seems to keep moving.

On January 19th, the Federal Motor Carrier Safety Administration (FMCSA) granted rental companies and their customers extra time to comply with the ELD mandate. Rental companies have an additional 90 days to provide ELD solutions on short-term rentals. This ELD rental truck exemption means short-term truck rentals (and drivers of short-term rental trucks) are temporarily ELD-exempt until April 19, 2018.

This extension is separate from an earlier decision by the FMCSA exempting short-term (eight days or less) truck rentals from ELD. That eight-day maximum exemption remains in-place, but won’t be enforced for another 90 days.

These exemptions apply only to short-term rentals. Long-term rentals (previously defined as 30 days or more) have long been in-scope for ELD.

These three factors (the eight-day exemption, definitions around “short-term,” and the 90-day waiver) have brought further confusion in the wake of the ELD mandate, which took effect in December 2017.

Let’s try to clear up some of that ELD confusion.

Rental Truck ELD Exemption

With things in constant motion around the ELD for rental trucks, it’s hard to keep up. Here’s a quick timeline of events:

March 2017: TRALA requests 30 day exemption for rental trucks.

October 2017: FMCSA grants exemption for rental trucks used for eight days or fewer, rather than the 30 days asked by TRALA

December 2017: FMCSA grants 90 day extension (until 4/19/2018) for short-term trucks, defined as 30 days or less

On January 19, 2018, TRALA submitted another petition to extend that rental exemption from eight to 30 days, and for it to remain in effect until December 31, 2018.

The FMCSA is currently reviewing this request. If granted, it would allow rental truck companies and their customers additional time -- through all of 2018 -- to prepare for the inevitable.

The ELD Road Ahead

The message to the many companies (and drivers) who currently rent trucks and haven’t embraced ELD: TRALA’s actions and the FMCSA’s decision bought you some time, but only a little bit.

Barring any unforeseen reversals by the FMCSA, your rental trucks will start requiring ELD on April 20th of this year. From that date onwards, all rentals of trucks in-scope for ELD lasting over eight days will require ELD’s.

“The message to the many companies (and drivers) who currently rent trucks and haven’t embraced ELD: TRALA’s actions and the FMCSA’s decision bought you some time, but only a little bit.”

However, stay tuned for updates. It’s been a wild ride, and it’s not over yet.