Driveaway-Towaway ELD Exemption: Paper Logs and Inspection Rules

If you drive in driveaway-towaway operations, you don’t need an electronic logging device as long as the vehicle you’re driving is itself the shipment being delivered. That is the entire driveaway-towaway ELD exemption in one sentence, and it comes straight from the driver’s record of duty status rule.¹ Instead of ELD hardware, you keep hours of service on paper logs or compliant logging software. The exemption is narrower than most drivers think, and the paperwork it leaves behind is enforced just as strictly as any ELD mandate.

When the Exemption Applies

Federal rules define a driveaway-towaway operation as the movement of an empty or unladen motor vehicle where at least one set of the transported vehicle’s wheels stays on the road surface during transit.² That covers a few common scenarios:

Moving a vehicle between manufacturing facilities, or from a manufacturer to a dealer or purchaser.
Transporting a vehicle from a dealership or leasing entity to a buyer or lessee.
Driving a damaged or disabled vehicle to a terminal or repair facility after a crash or breakdown.
Any movement using a saddle-mount or tow-bar coupling, regardless of the transaction.

On top of that definition, the ELD exemption adds one more condition: the vehicle being driven must be part of the shipment being delivered.¹ In plain terms, the truck on the road has to function as a commodity in a commercial transaction, not as equipment hauling something else. A new tractor being delivered from the factory to a dealer qualifies. That same tractor pulling a trailer of consumer goods does not, even if it was originally acquired as a dealer delivery.

Where the Exemption Ends

The moment the vehicle carries unrelated cargo for compensation, the exemption disappears and full ELD requirements apply.³ There is no split-trip version where part of the run counts and part doesn’t. If any portion of the movement involves hauling freight, you need an ELD for the entire trip.

This is the point that trips people up. A driver relocating an empty chassis from an auction to a dealership qualifies, because the chassis is the item being sold. The same driver using that chassis to pull freight along the way does not qualify, at all, for that trip.

Hours of Service Still Apply

The exemption changes only how you record your hours. It does not change the limits themselves. Driveaway-towaway drivers are subject to the same 11-hour driving limit, 14-hour on-duty window, and mandatory rest breaks as any other property-carrying CMV driver.³ Blow through those limits and you’ll be placed out of service whether your logs are electronic or on paper.

Some drivers treat the ELD carve-out as broader deregulation. It isn’t. An inspector comparing your odometer readings to your recorded mileage, then cross-referencing fuel receipts and dispatch records, will catch a padded paper log as fast as an ELD data file flags an anomaly.

What Your Paper Log Must Contain

Under the exemption, you record duty status manually for each 24-hour period, and the record must be prepared in duplicate.¹ One copy goes to the carrier; you keep the other. Each record must include:

The date (month, day, year) for the start of the 24-hour period.
Total miles driven during that 24-hour period.
The motor carrier’s name and main office address.
The carrier-assigned unit number, or the license plate number and issuing state, for each vehicle operated.
A 24-hour graph grid showing time in each duty status (off-duty, sleeper berth, driving, on-duty not driving), with notations at each location where a status change occurred.
The driver’s signature certifying that all entries are true and correct.

Standard paper logbooks are sold at most truck stops. Logging software that produces compliant output is also acceptable.³ Whichever you use, the content requirements are identical.

Supporting Documents You Need at an Inspection

Paper logs alone don’t tell the full story, and inspectors know it. You are required to carry supporting documents that corroborate your recorded duty status. FMCSA recognizes five categories:⁴

Bills of lading or itineraries showing origin and destination.
Dispatch or trip records.
Expense receipts related to on-duty not-driving time.
Electronic communication records, such as fleet management messages.
Payroll records or settlement sheets.

Each document must include your name or carrier-assigned ID, the date, the location (nearest city or town), and the time. If you have fewer than eight documents that carry all four elements, a document missing only the time still counts.⁴ For driveaway-towaway work in particular, the bill of lading or delivery receipt is the document that matters most, because it proves the vehicle is the commodity being delivered. Without it, you’re asking an inspector to take your word that the truck you’re sitting in is the shipment rather than equipment.

Submitting and Keeping Records

After a trip ends, you must submit the original records to the carrier within 13 days of the 24-hour period each record covers.¹ That is where the duplicate matters: the carrier gets the original, you keep the copy.

You must retain copies of the previous seven consecutive days of records and have them ready for inspection while on duty.¹ The carrier keeps all submitted records and supporting documents for at least six months from the date of receipt. At a roadside inspection, expect the officer to ask for the current day’s log plus the previous seven, and to compare your odometer readings and mileage against your fuel receipts and dispatch records.

Penalties for Bad Logs

Federal civil penalties for incomplete, inaccurate, or missing records of duty status can reach $1,584 per day for each day the violation continues, with a ceiling of $15,846.⁵ Knowingly falsifying a record carries the same maximum. These amounts are adjusted periodically for inflation, so confirm the current figures in the Federal Register.

Fines aren’t the whole exposure. Falsified or missing logs can get you placed out of service at a roadside inspection, meaning the trip stops right there until the violation is corrected or the required off-duty time is served. Carrying a printed copy of 49 CFR § 395.8 can help resolve confusion with an inspector who isn’t familiar with the driveaway-towaway exemption, but no amount of paperwork rescues a log that doesn’t match reality.

If You Only Do Driveaway Work Occasionally

A separate exemption lets any driver who uses paper logs on eight or fewer days within a 30-day period skip the ELD requirement entirely.⁶ If you split your time between driveaway runs and regular freight, the 8-day rule may already cover your driveaway days without your ever needing to invoke the driveaway-specific exemption. FMCSA treats the two as independent, so you can rely on whichever fits the situation you’re actually in.

1
eCFR. 49 CFR 395.8 – Driver’s Record of Duty Status
2
eCFR. 49 CFR 390.5 – Definitions
3
Federal Motor Carrier Safety Administration. Who Is Exempt from the ELD Rule?
4
Federal Motor Carrier Safety Administration. Supporting Documents
5
eCFR. 49 CFR Part 386 – Rules of Practice for FMCSA Proceedings – Appendix B
6
Federal Motor Carrier Safety Administration. Electronic Logging Device (ELD) Exemptions, Waivers and Vendor Malfunction Extensions