Understanding Wisconsin's Intrastate ELD Requirements

In March 2024, Wisconsin issued a final rule requiring the use of electronic logging devices (ELDs) by intrastate motor carriers and drivers, with compliance required by April 1, 2025.

Though motor carriers have about a year to convert from paper logs to ELDs, the process should begin as soon as possible to ensure compliance. Have questions? We have answers…

Q&A

Question: Who does Wisconsin’s ELD mandate apply to?

Answer: In Wisconsin, intrastate (not crossing state lines, not furthering interstate commerce) compliance with the hours-of-service regulations, including the ELD mandate, applies to drivers who operate:

• A single vehicle with a gross vehicle weight rating of 26,001 or more pounds or registered weight or actual gross weight of more than 26,000 pounds;
• A combination vehicle with a gross combination weight rating, registered weight or actual gross weight of 26,001 or more pounds inclusive of a towed unit with a gross vehicle weight rating, registered weight or actual gross weight of more than 10,000 pounds;
• A vehicle transporting hazardous materials requiring placarding or any quantity of a material listed as a select agent or toxin under 42 CFR 73;
• A vehicle designed to transport or actually transporting the driver and 15 or more passengers.

Question: Can my intrastate drivers use the same make and model of ELDs as my interstate drivers?

Answer: Yes. The final rule requires the use of devices that meet the requirements in Part 395, Subpart B of the Federal Motor Carrier Safety Regulations (FMCSRs).

Question: Are there exceptions to the ELD requirement?

Answer: There are exceptions to the ELD requirement for:

• A driver operating a commercial motor vehicle in a manner requiring completion of a record of duty status on not more than 8 days within any 30-day period;
• A driver involved in a driveaway-towaway operation in which the vehicle being driven is part of the shipment being delivered;
• A vehicle manufactured before model year 2000, as reflected in the vehicle identification number (VIN) and as shown on the vehicle’s registration; and
• A motor carrier, driver, or vehicle subject to federal regulatory guidance, a waiver, or an exemption issued by the Federal Motor Carrier Safety Administration (FMCSA) which specifically exempts the use of an ELD.

Question: My intrastate drivers use 150 air-mile radius exception? Do they need to use an ELD?

Answer: If your drivers meet the 150 air-mile radius exception criteria, an ELD is not required. Do note though, if your drivers can't meet the exception’s criteria and must complete a record of duty status on more than 8 days within any 30-day period, the ELD would be required.

Parting Thought

On April 1, 2025, intrastate operations in Wisconsin must comply with the ELD requirements. Carriers should begin the implementation process now to ensure full compliance by April 1, 2025.