ELD Exemption: FOPT Requests to Use Paper Logs

FMCSA Opens Review of ELD Exemption Request

The Federal Motor Carrier Safety Administration (FMCSA) has opened a public comment period on a request that could change how some truck drivers record their hours of service. The request involves an ELD exemption that would allow drivers to use paper logbooks instead of electronic logging devices. The notice was published in the Federal Register and is now open for public review.

FMCSA is accepting comments on the request through March 11, 2026.

ELD Exemption Request Filed by Trucking Advocacy Group

The ELD exemption request was submitted by the Federation of Professional Truckers (FOPT). FOPT describes itself as a nonprofit advocacy organization representing professional drivers and small motor carriers across the United States.

FOPT is asking FMCSA to grant an exemption from federal rules that require drivers to use electronic logging devices to record records of duty status, also known as RODS.

If approved, the ELD exemption would apply to FOPT members and to any other professional driver who chooses to participate.

Current Federal Rules Governing ELD Use

Under current federal regulations, drivers who are required to prepare records of duty status must generally use an electronic logging device. These rules are found in federal hours-of-service regulations.

There is a limited exception for drivers who only need to complete records of duty status on eight or fewer days within any 30-day period. Outside of that narrow exception, ELD use is required.

The requested ELD exemption would go beyond the existing limited exception. Drivers operating under the exemption would still be required to follow all other hours-of-service rules.

What the Requested ELD Exemption Would Allow

If FMCSA grants the ELD exemption, participating drivers would be allowed to record their hours using paper logbooks instead of electronic devices.

The exemption would be optional. Drivers would not be required to use paper logs. Instead, they would be given the choice.

All other safety rules would remain in place. This includes limits on driving time, required rest periods, and compliance with hours-of-service regulations.

FMCSA has not approved or denied the request. The agency is still in the review stage.

Reasons Given for the ELD Exemption Request

In its application, FOPT argues that paper logbooks remain an enforceable method of tracking hours of service. The organization states that paper records are widely understood by roadside enforcement officers across the country.

FOPT also raises concerns about the financial impact of ELD systems on small carriers and independent drivers. According to the application, these costs can fall harder on smaller operations.

The request also points to technical issues tied to electronic logging devices. These include malfunctions, system failures, and other technical limits that may interfere with compliance.

FOPT further notes that federal policy encourages agencies to avoid unnecessary regulatory burdens when reasonable alternatives exist.

Safety Measures Proposed Under the ELD Exemption

FOPT states that the ELD exemption would not reduce safety. The organization outlines several steps it would take to support compliance.

According to the application, FOPT would provide education to drivers on how to properly complete paper records of duty status. The goal would be to ensure accuracy and consistency.

Participating motor carriers would also be expected to conduct random internal audits of paper logbooks. These audits would be used to identify errors or violations.

FOPT states that drivers who violate hours-of-service limits while using paper logs would be removed from the exemption program.

How FMCSA Reviews an Exemption Request

FMCSA has authority under federal law to grant exemptions from motor carrier safety regulations. Before granting any ELD exemption, the agency must determine that safety would be equal to or greater than current rules.

Federal law requires FMCSA to publish exemption requests in the Federal Register. The public must be given the chance to review the request and submit comments.

FMCSA will review the application, safety analysis, and all public comments before issuing a decision.

If approved, the agency would publish the terms, conditions, and length of the ELD exemption. If denied, FMCSA would explain the reasons for the decision. Approved exemptions may later be renewed.

Public Comment Period Open

FMCSA is accepting public comments on the ELD exemption request through March 11, 2026. All submissions must reference Docket No. FMCSA-2025-1282.

Comments may be submitted through the federal rulemaking website, by mail, by fax, or by hand delivery to the Department of Transportation in Washington, D.C.

FMCSA notes that all comments received will be posted publicly without editing. Any personal information included in a comment will be visible to the public.

What Happens Next in the ELD Exemption Process

After the comment period closes, FMCSA will review all timely submissions. The agency may also add relevant information to the public docket as it becomes available.

No timeline has been announced for a final decision on the ELD exemption request.

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