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A Common Misunderstanding about CDLs and Vehicle Weight

February 2016

We often encounter individuals who believe a CDL is required if a truck and tow vehicle’s Gross Combined Weight Rating exceeds 26,000 lbs. or if the trailer’s Gross Vehicle Weight Rating exceeds 10,000 lbs. But this is not exactly true…

If you review the Code of Federal Regulations* section that defines Commercial Motor Vehicle Groups, you’ll find a statement similar to the one above. It reads:

“Combination Vehicles (Group A) - any combination of vehicles with a gross combination weight rating (GCWR) of 11,794 kilograms or more (26,001 pounds or more) provided the GVWR of the vehicle(s) being towed is in excess of 4,536 kilograms (10,000 pounds).”
49 CFR 383.91

Did you notice the difference? The phrase that connects the two requirements is not “or”, it’s “provided”. A small turn of phrase, but the distinction is significant. If just one of the requirements is not met, then a CDL is not required. Going back to the first statement in this article, a more accurate version would read something like: “A CDL is required if a truck and tow vehicle’s GCWR exceeds 26,000 lbs. and if the trailer’s GVWR exceeds 10,000 lbs.” Both conditions need to be met to require a CDL.

Of course, there are exceptions to every rule. In the same section, a few rows down, it’s clear that a CDL is required when transporting Hazardous Materials that require placarding, regardless of vehicle weight.

“Small Vehicle (Group C)—Any single vehicle, or combination of vehicles, that meets neither the definition of Group A nor that of Group B as contained in this section, but that either is designed to transport 16 or more passengers including the driver, or is used in the transportation of hazardous materials as defined in §383.5.”
49 CFR 383.91
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Thunder Creek fuel trailers can be built to remain below the GVWR and/or GCWR thresholds. We’ve also the developed the unique Multi-Tank Trailer – a bulk fuel trailer constructed in a way that does not require placarding - therefore legally mitigating the need for the driver to carry a HAZMAT endorsement.

 
*The information is this article is based on the federal requirements found in the CFR. State and local entities have the authority to regulate above and beyond the federal standards. California and Delaware, for example, have enacted rules that require the CDL any time the trailer GVWR exceeds 10,000 lbs., regardless of GCWR.

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