Short Haul Exemption to the ELD Mandate — Who Qualifies and How to Document It

A lot of regional and local carriers bought ELDs they didn't actually need — because they didn't understand the short-haul exemption, or their insurer pressured them, or they just defaulted to full compliance without checking whether the mandate applied.

If you operate within a relatively tight geographic area and return to your home base every day, you may qualify for the short-haul exemption to the federal ELD mandate. Here's the full qualification test, what you have to keep instead, and where carriers go wrong.

What the ELD Mandate Actually Requires

The federal ELD mandate, effective for most carriers since 2019, requires commercial drivers to record their hours of service on an FMCSA-registered electronic logging device rather than paper logs.

The requirement applies broadly — but with specific exemptions written into the HOS rules. The short-haul exemption (also called the 100 air-mile radius exemption) is the most commonly applicable one for local and regional owner-operators.

The Short-Haul Exemption for CDL Holders (49 CFR 395.1(e)(1))

For CDL holders operating in interstate commerce, the short-haul exemption requires that you meet all of the following conditions on a given day:

Condition 1: Same Start and End Location

You must report to and return to the same work reporting location within the same 24-hour period. If your work reporting location is your home address, your terminal, or your company's yard — you must start and end there.

A driver who stays overnight at a shipper's facility or a truck stop, even once, cannot use the short-haul exemption for that day.

Condition 2: 100 Air-Mile Radius

You must operate within a 100 air-mile radius of your work reporting location. Air miles are straight-line distance — not road miles. A destination 95 road miles away may be only 70 air miles; a destination 95 road miles away in a winding route may still be 85 air miles.

If you're unsure whether a destination is within 100 air miles, calculate the straight-line distance. FMCSA uses air miles, not driving miles. Exceeding the radius — even by a few miles — disqualifies you from the exemption for that day.

Condition 3: 12 Consecutive Hours

You must return to your work reporting location within 12 consecutive hours of your start time. Hours of service limits still apply — you still can't exceed the driving time limits in 49 CFR 395.3. The exemption just allows you to avoid paper or ELD logging.

If you end up working more than 12 consecutive hours before returning, the exemption doesn't apply for that day.

Condition 4: HOS Compliance in Prior 7 Days

You must not have exceeded the allowable hours in the preceding 7 consecutive days. If you violated HOS rules in the past week, you don't qualify for the short-haul exemption until you've had a valid restart.

This condition catches drivers who run hard all week and then try to use the exemption on a day they're technically over the weekly limits.

Condition 5: Adequate Time Off Between Shifts

You must have had at least 10 consecutive hours off duty before the current work shift begins. This mirrors the standard HOS requirement for the 11-hour driving rule.

What You Keep Instead of Logs

If you meet all five conditions, you don't need an ELD and you don't need to keep paper logs for those days. What you must keep instead:

Time records showing:

• Time you reported for duty
• Time you were released from duty
• Total hours for the day

These records must be kept for 6 months and must be available to DOT inspectors on request. No specific form is required — a simple daily log showing in/out times is sufficient. Payroll records or time-clock records may satisfy this if they capture the right information.

The simplicity of time records vs. ELD data or paper logs is the operational benefit of the exemption. No grid log, no log reconstruction, no 70-hour clock to track.

The 150 Air-Mile Exemption for Non-CDL Drivers (49 CFR 395.1(e)(2))

There's a separate, slightly wider exemption for drivers who do not hold a CDL. These drivers can operate within a 150 air-mile radius of the work reporting location under similar conditions: same-day return, adequate time off, and no HOS violation in the prior 7 days.

If you're using owner-operators or independent contractors under your authority who don't hold CDLs (which is unusual in trucking but does happen in certain specialized operations), this exemption has a wider radius.

For most trucking discussions, the CDL holder's 100 air-mile exemption is the relevant one.

What Disqualifies You — On a Given Day

The exemption is applied day by day. Meeting the criteria five days a week doesn't protect you on the two days you don't. On any day you:

• Drive beyond 100 air miles from your work reporting location
• Don't return to your start location within 12 hours
• Were over HOS limits in the previous 7 days

...you must maintain a full record of duty status for that day. If you're using the short-haul exemption and you realize partway through the day that you won't make it back in time, you must start logging immediately — reconstructing duty status from the moment you started.

What This Means for ELD Equipment

If you qualify for the short-haul exemption on most or all of your working days, you may not be required to operate an ELD. That said, several practical factors affect the decision:

Insurance requirements: Your insurer may require an ELD regardless of regulatory requirements. This is common for fleet policies and worth checking before you remove the device.

Broker requirements: Some brokers or shippers specify ELD compliance in their carrier agreements. Review any such requirements in contracts you're operating under.

Mixed operations: If you run regional freight on most days but occasionally haul interstate loads beyond 100 air miles, you need an ELD available for those non-exempt days. Many carriers in this situation keep an ELD installed and simply don't log on qualifying short-haul days.

Consistency in documentation: An ELD that records everything automatically may be easier to maintain than tracking which days qualify for the exemption and which require manual documentation. This is a legitimate operational consideration, not just a compliance one.

Tracking Your Operations Against the Criteria

The practical challenge with the short-haul exemption is knowing — in real time — whether you're within the 100 air-mile radius and whether you'll be back within 12 hours. Dispatching decisions that keep you near the boundary of the radius or close to the 12-hour limit create uncertainty about your documentation obligations.

Dispatching that records where each load takes you and what time you depart and return helps you verify after the fact whether a given day qualified for the exemption. That record is what you'd present to a DOT inspector who asks why you're not running an ELD.

Compliance tracking that logs your hours worked and flags potential HOS concerns helps you catch the "prior 7 days" condition before you unknowingly disqualify yourself from the exemption.

The Audit Question

When a DOT auditor reviews your operation and sees you're running without an ELD, the first question is whether you qualify for a recognized exemption. For short-haul operators, that means:

• Demonstrating that your routes operate within 100 air miles
• Showing time records for 6 months back
• Being able to explain the conditions you're relying on

An operator who can't explain why they don't have an ELD — or who has spotty time records — creates compliance exposure even if they were technically operating within the exemption requirements. The documentation is what makes the exemption defensible.

Other ELD Exemptions Worth Knowing

The short-haul exemption is the most broadly applicable, but FMCSA also provides exemptions for:

• Driveaway-towaway operations: Where the vehicle being driven is itself the commodity
• Vehicles manufactured before 2000: Model year 2000 and older are exempt because compatible ELDs don't exist for all older engine types
• Agriculture: Certain agricultural operations have specific exemptions during planting and harvest seasons

If your operation doesn't fit cleanly into short-haul, these exemptions may be worth reviewing against your specific situation.

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