2025 Pub. 7 Issue 4

UNDERSTANDING DOT REQUIREMENTS FOR VEHICLES BY GROSS VEHICLE WEIGHT RATING (GVWR) BY JAY O’LEARY GOVERNMENT RELATIONS & COMPLIANCE SPECIALIST, NHADA Navigating U.S. Department of Transportation (DOT) requirements can be confusing, especially for businesses that sell or service medium- and heavy-duty trucks. Knowing when and how these rules apply is critical to staying compliant and avoiding penalties. This resource outlines the key requirements based on Gross Vehicle Weight Rating (GVWR) and clarifies how they affect your employees, vehicles and operations. WHAT IS GVWR AND WHY DOES IT MATTER? The GVWR is the maximum total weight a vehicle is rated to safely carry, including the vehicle itself, passengers, cargo and fuel. DOT requirements are tied directly to GVWR thresholds. • Over 10,000 lbs. GVWR: Certain DOT requirements apply when vehicles are operated for commerce. • Over 26,000 lbs. GVWR: Commercial Driver’s License (CDL) is required. WHO IN YOUR BUSINESS IS AFFECTED? DOT requirements don’t only apply to full-time drivers. At a dealership, service center or repair shop, affected employees often include: • Service technicians test-driving vehicles after repairs or computer resets. • Sales staff taking a customer on a test drive. • Parts runners or other employees operating company-owned vehicles for deliveries. If the vehicle is used on public roads for business purposes (commerce), DOT rules apply. The only exemption is when the vehicle is operated solely on your facility’s lot (e.g., plowing snow onsite). KEY DOT REQUIREMENTS FOR VEHICLES OVER 10,000 LBS. GVWR Even if a CDL is not required, the following obligations generally apply: 1. Driver Medical Certification • Operators must pass a DOT physical every two years. • If passed, they receive a medical card, which must be carried at all times while driving. 2. Vehicle Requirements • An annual inspection is required. • Vehicles must be in proper working order (brakes, lights, etc.). • If company-owned: » Must display company markings. » Must carry a secured, accessible fire extinguisher. » Maintenance records must be kept. » At least $1 million in insurance is required if vehicles are being hauled. » If crossing state lines, the vehicle must display the company’s DOT number. 3. Driver Qualification File Employers must maintain a file for each driver, including: • Job application. • Copy of the medical card. • Other supporting compliance documents. 12

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