The electronic logging device mandate that went into full effect last December had a number of exemptions, and one of them was for older engines that might not have the level of electronics needed.
Running Pre-2000 Engines, Paper Logs Calls for Right Documentation
The electronic logging device mandate that went into full effect last December had a number of exemptions, and one of them was for older engines that might not have the level of electronics needed.

Make sure if you’re using a pre-2000 engine in a newer truck that you have plenty of documentation.
Photo: Deborah Lockridge
But just because you’re exempt doesn’t mean you’ll automatically sail through roadside inspections or back-office compliance reviews – especially if you’re running an older engine in a glider kit that has allowed you to update the cab while keeping the older engine.Originally, the ELD rule said it offered an exemption for “Drivers of vehicles manufactured before model year 2000,” and in fact you’ll still find that wording on certain government sites.
The reason was that older engines did not have the same level of sophisticated electronics that could feed the needed data to the ELD. But the original wording didn’t take into account that some truckers like to install older engines out of wrecked trucks into newer cabs via glider kits, so FMCSA clarified that exemption to reflect that it refers to the engine model year, not the model year in the truck’s VIN number.
So whether you’re driving a 1998 truck with the original engine or you have a 2018 glider kit with a 1998 engine, you aren’t required to use an ELD.
According to an FMCSA FAQ, “While the driver is not required to possess documentation that confirms the vehicle engine model year, 49 CFR Part 379 Appendix A requires motor carriers to maintain all documentation on motor and engine changes at the principal place of business.”
However, just what that documentation should consist of may be subject to interpretation by the particular investigator doing a compliance review, says John Seidl, who provides DOT transportation consulting to motor carriers as vice president of risk services for insurance provider Reliance Partners.
One of Seidl’s clients last year received a conditional safety rating and a $15,000 fine for “failing to require a driver to prepare a record of duty status using the appropriate method.” Their crime? Drivers were using paper logbooks because their trucks’ engines were built prior to 2000. The compliance review said the drivers were using paper logs but had “no documentation to show engine is manufactured prior to 2000.”
“He had a glider kit, but nothing to tie the engine to the paperwork,” Seidl says. “FMCSA didn’t like that there was just a piece of paper saying it was a glider with a pre-2000 engine. They wanted a physical tie to the engine to support the paperwork,” he said, although there’s nothing in the law spelling out that requirement. That 49 CFR Part 279 Appendix A simply says, “records of motor and engine changes.”
So Seidl worked with the small fleet to gather documentation for all its trucks with pre-2000 engines, such as:
Printed paperwork from glider kit manufacturers and engine rebuilders showing the pre-2000 original engine build dates.
ECM download from the trucks showing the engine serial number and the truck VIN, linking that engine build date to the VIN
Registration cards showing the corresponding VIN for the truck
“If you’re running a glider, you’d better not only have paperwork, but try to tie that pre-2000 engine to the paperwork you have,” Seidl advises. “Get pictures of the engine serial numbers that match the paperwork, ECM downloads that match the paperwork. If you’re running a 1996 truck, a registration card will usually do. But if the registration card says it’s a 2015 Freightliner and you’re trying to say you have a ’99 engine, this particular investigator in this state would not accept mere paperwork.”
More Safety & Compliance

Nominations Open for HDT Truck Fleet Innovators 2026
Heavy Duty Trucking is searching for forward-looking leaders at trucking fleets as nominations for HDT’s Truck Fleet Innovators 2026. Deadline is May 15.
Read More →
Freightliner Expands Detroit Assurance with New Intersection and Turning Safety Tech
Detroit’s next-generation ABA6 safety system adds cross-traffic detection and enhanced side guard assist with left-turn protection, targeting high-risk urban scenarios.
Read More →
'Beyond Compliance,' Regulations, Driver Coaching on ATRI’s 2026 Research List
The American Transportation Research Institute will examine driver coaching, regulatory impacts — including the "Beyond Compliance" concept —and weather disruptions that shape trucking operations.
Read More →
FMCSA Revamps DataQs to Improve Fairness, Speed of Reviews
New requirements add firm deadlines and independent review steps, addressing long-standing complaints about inconsistent rulings and slow response times.
Read More →
FMCSA Extends Paper Medical Card Exemption … Again
Five states still aren't ready to accept commercial driver medical exam information directly from the medical examiner's registry.
Read More →
HDT Honors the Best New Products of 2025 at TMC [Photos]
Heavy Duty Trucking's Top 20 Products awards recognize the best new products and technologies. Check out the award presentations at the 2026 Technology & Maintenance Council annual meeting.
Read More →
Detroit Engines: Trusted Performance, Built for What's Next
The Detroit® Gen 6 engine platform proves that real progress doesn’t require a complete redesign. Built on 20 years of trusted technology, these engines are designed for efficiency, stronger performance, and greater reliability than before. And they do it all while complying with 2027 EPA standards on every mile.
Read More →
Aperia Expands Halo Platform with Steer-Tire Inflation System, Fifth-Wheel Integration
Aperia Technologies introduced a new automatic tire inflation system for steer axles and a partnership with Fontaine Fifth Wheel to integrate coupling status into its Halo Connect platform.
Read More →
Fleetworthy and HAAS Alert Expand Partnership Stopped Truck Protection Alerts
Fleetworthy and HAAS Alert expanded their partnership to deliver real-time digital alerts that warn motorists when commercial trucks are stopped roadside and notify truck drivers when approaching emergency responders.
Read More →
New Entrants, Chameleon Carriers, and Safety: Is It Too Easy to Start a Trucking Company?
More than 100,000 new trucking companies enter the industry each year, but regulators manage to audit only a fraction of them. That churn creates opportunities for inexperienced startups — and for “chameleon carriers” that shut down after safety violations and reappear under new identities. Read more from Deborah Lockridge in this commentary.
Read More →
