NOTE:  This guidance revises FMCSA-ELD-Functions-FAQs(2018-04-09), issued on April 9, 2018, and rescinded on March 10, 2022.

FMCSA-ELD-Functions-FAQs(2022-03-10)

ELD Functions FAQs

Question: What information is automatically recorded by an electronic logging device (ELD)?

Guidance: An ELD automatically records the following data elements at certain intervals: date; time; location information; engine hours; vehicle miles; and identification information for the driver, authenticated user, vehicle, and motor carrier.

Question: When is location data recorded by an electronic logging device (ELD)?

Guidance: Location data must be recorded by an ELD at 60-minute intervals when the vehicle is in motion, and when the driver powers up and shuts down the engine, changes duty status, and indicates personal use or yard moves.

Question: As a motor carrier, how can I be sure an electronic logging device (ELD) is compliant? 

Guidance: The motor carrier is responsible for checking that their device is registered, as established in 49 CFR 395.22. Motor carriers should only purchase an ELD that is self-certified by the manufacturer to be compliant and that is registered and listed on the FMCSA website. 

The list of registered ELDs can be found at https://eld.fmcsa.dot.gov/List. Motor carriers should also familiarize themselves with the ELD checklist and the ELD rule.
In the event that an ELD is removed from the registration list, FMCSA will place the removed device on FMCSA’s Revoked ELDs List.

Question: What does engine synchronization mean for the purposes of electronic logging device (ELD) compliance?

Guidance: An ELD must be integrally synchronized with the engine of the commercial motor vehicle (CMV). Engine synchronization means monitoring engine operation to automatically capture the engine power status, vehicle motion status, miles driven, and engine hours.

Question: How must a driver be able to access records of duty status (RODS) from an electronic logging device (ELD)?

Guidance: Since all ELD data file output will be a standard comma-delimited file, a driver may import the data output file into Microsoft Excel, Word, notepad, or other common tools. A driver will also be able to access ELD records through a screen display or a printout, depending on the ELD design.

Question: How does the electronic logging device reflect personal conveyance when the personal conveyance status is selected and the commercial motor vehicle (CMV) is driven?

Guidance: When the personal conveyance status is selected (as allowed and configured by the motor carrier), the CMV’s location is recorded with a lower level of precision (i.e., an approximate 10-mile radius). Personal conveyance will be reflected on the ELD using a different style line (such as dashed or dotted line).

Question: What are the display requirements for team drivers using the same electronic logging device (ELD) on their commercial motor vehicle (CMV)?

Guidance: In the event of team drivers, the ELD must display the data for both co-drivers who are logged into the system.

Question: Can a logged-in co-driver make entries over his or her records using the electronic logging device (ELD) when he or she is not driving?

Guidance: Yes. The driver who is not operating the vehicle may make entries over his or her own records when the vehicle is in motion. However, co-drivers cannot switch driving roles on the ELD when the vehicle is in motion.

NOTE: The following guidance reflects minor correction(s) (e.g., for grammar, typographical errors, or consistency) made on March 10, 2022.

Question: Will the vehicle location information identify street addresses?

Guidance: No. Vehicle location information is not sufficiently precise to identify street addresses. For each change in duty status, the electronic logging device (ELD) must convert automatically captured vehicle position in latitude/longitude coordinates into geo-location information that indicates the approximate distance and direction to an identifiable location corresponding to the name of a nearby city, town, or village, with a State abbreviation.

Question: Is an electronic logging device (ELD) required to collect data about vehicle performance?

Guidance: No. ELDs are not required to collect data on vehicle speed, braking action, steering function, or other vehicle performance parameters. ELDs are only required to collect data to determine compliance with hours of service (HOS) regulations.

Question: Do the specifications in the electronic logging device (ELD) rule for ELDs include requirements to automatically control the vehicle, such as other safety systems that may or apply braking?

Guidance: No. The specifications for ELDs do not include requirements to control the vehicle. An ELD is a recording device that records vehicle parameters through its synchronization to the vehicle’s engine, and allows for entries related to a driver’s record of duty status (RODS).

Question: What is the level of accuracy for commercial motor vehicle (CMV) location information recorded by an electronic logging device (ELD)?

Guidance: During on-duty driving periods, the location accuracy is approximately within a 1-mile radius. When a driver operates a commercial motor vehicle (CMV) for personal use, the position reporting accuracy would be approximately within a 10-mile radius.

Question: Will GPS-derived data for mileage be allowed as a substitute for data that cannot be readily obtained from a vehicle electronic control module (ECM)?

Guidance: No, the electronic logging device (ELD) must be able to monitor engine operation to automatically capture required data. A global positioning system (GPS) is not integrally synchronized with a vehicle’s engine and cannot be a substitute for required ECM data to comply with the ELD rule.

Question: Can an electronic logging device (ELD) have a feature to warn drivers about approaching hours of service limits?

Guidance: Yes. FMCSA allows, but does not require, warning or notification to drivers when they are nearing their hours of service limits.

Question: When will an electronic logging device (ELD) automatically start to record a driving mode or status?

Guidance: An ELD must automatically switch to driving mode once the commercial motor vehicle (CMV) is moving up to a set speed threshold of 5 miles per hour. As a result, the in-motion state must not be configured greater than 5 miles per hour. The vehicle will be considered stopped once its speed falls to zero (0) miles per hour and stays at zero (0) miles per hour for 3 consecutive seconds.

Question: When will an electronic logging device (ELD) automatically change the duty status from Driving to the default duty status of On-Duty Not Driving?

Guidance: When the duty status is set to Driving, and the commercial motor vehicle (CMV) has not been in motion for 5 consecutive minutes, the ELD must prompt the driver to confirm a continued driving status or enter the proper duty status. If the driver does not respond to the ELD prompt within 1 minute, the ELD must automatically switch the duty status to On-Duty Not Driving.

Question: Can an electronic logging device (ELD) record be set to record minimum duty status durations, such as 15 minutes?

Guidance: No. The ELD will capture all entered duty statuses, and there is no minimum amount of time that these statuses must or should be engaged. While longstanding industry and enforcement practices may have relied upon minimum intervals of 15 minutes in handwritten record of duty status (RODS), an ELD provides a more accurate accounting of drivers’ time. This should not be construed to indicate that the activities electronically recorded as less than 15 minutes are suspect, only that the time actually required to complete the task may be less than what had been traditionally noted in the paper RODS.

Question: May an electronic logging device (ELD) be used to track mileage for tax reporting purposes?

Guidance: The device manufacturer may offer that service as part of a fleet management package but mileage tracking for tax reporting purposes is not part of the ELD data established in 49 CFR part 395.
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Note: This guidance document does not have the force and effect of law and is not meant to bind the public in any way.  It is intended only to provide information and clarity regarding existing requirements under the law or agency policies.