Do I Need a DOT Number? Navigating DOT & FMCSA Requirements for Rentals
Commercial truck rentals let your business flex its fleet up and down as needed. But before you roll off the lot with your vehicle, you need to know which regulations apply. Here’s a quick guide on the most important U.S. Department of Transportation (DOT) and Federal Motor Carrier Safety Administration (FMCSA) requirements for rental trucks.
Obtaining a DOT Number
A DOT number must be requested by the motor carrier if required by FMCSA regulations. DOT uses the number to track a company’s safety record and compliance. Some – but not all – rental trucks will need a DOT number. How can you tell for sure? Start by asking these three questions:
- Will I cross state lines while using the rental truck? Any commercial motor vehicle (CMV) rental used for interstate commerce must have a DOT number.
- Does the rental vehicle carry a gross vehicle weight rating (GVWR) of 10,001 pounds or more? If yes, you will likely need a DOT number, even for intrastate use, depending on your state’s regulations.
- Will I transport hazardous materials? If so, you’ll need a DOT number and the appropriate placards to comply with DOT’s Hazardous Materials Regulations.
If you’re unsure whether you’ll need a DOT number, check both state and federal regulations and ask your Penske representative for guidance. Should you need a DOT number, you can apply for it through the FMCSA’s Unified Registration System (URS).
DOT Number vs. Motor Carrier Number: What’s the Difference?
Most commercial rentals require only a DOT number. However, for-hire carriers transporting federally regulated commodities (such as certain chemicals, food products or household goods) across state lines will also need a Motor Carrier (MC) number, also called an “interstate operating authority.” The FMCSA issues all MC numbers.
Examples of businesses needing both a DOT and MC number include:
- Freight carriers transporting goods for hire across state lines
- Moving companies hauling household goods for paying customers interstate
- Courier services delivering time-sensitive parcels across state lines for compensation
Businesses needing an MC number can apply for it through the FMCSA’s URS. While DOT numbers can be obtained within hours, MC number approval usually takes several weeks.
ELD Requirements for Commercial Rentals
Under the FMCSA’s ELD mandate, covered rental vehicles must use electronic logging devices (ELDs) to track drivers’ Record of Duty Status (RODS) and Hours of Service (HOS). RODS are logs tracking a driver’s on-duty and off-duty hours. HOS limits determine how long drivers can operate a vehicle without a break.
All drivers of commercial rental vehicles must track their RODS and HOS, and most commercial rentals will need ELDs. However, a short-term rental exemption allows drivers of rental vehicles to use paper logs instead of ELDs if the rental is used for eight days or fewer. With a short-term commercial rental from Penske, drivers can choose from using paper logs, a portable ELD or the Penske Driver™ App.
The Penske Driver app allows drivers to track their RODS and HOS, keeping fleets fully compliant with the ELD mandate. The app also lets drivers request 24/7 Roadside Assistance, submit fuel receipts digitally, find fueling and parking locations, and much more.
7 More Ways To Stay DOT & FMCSA Compliant With Your Rental Truck
Use these additional tips to maintain full DOT and FMCSA compliance while operating your Penske commercial rental vehicle:
- Determine whether you’ll need a Commercial Driver’s License (CDL). This handy guide on CDL vs. non-CDL truck rentals breaks down which rentals require a CDL and which ones don’t.
- Carry proper documentation. Display the DOT number on the vehicle (a taped sign is acceptable for temporary use) and keep the rental agreement in the vehicle at all times.
- Conduct pre- and post-trip vehicle inspections. While Penske performs DOT compliance inspections, drivers must conduct daily checks to ensure their rental vehicle remains in safe operating condition. Thorough pre- and post-trip inspections, required by DOT, help prevent unexpected delays and breakdowns.
- Know the rules on fatigue, health and wellness. The FMCSA prohibits drivers from beginning or continuing to drive if they are fatigued or have a medical condition that could interfere with the safe operation of a CMV. This is true even if the driver has a valid DOT medical certificate.
- Practice safe driving behaviors. Encourage drivers to avoid speeding, distracted driving and other dangerous activities while operating a rental vehicle. Need a refresher on defensive driving and other best practices? Penske offers monthly safety bulletins filled with practical tips to keep drivers and their cargo protected.
- Check state compliance regulations. Each state has its own rules regarding DOT numbers and other compliance-related topics. Be sure to review the regulations in every state where you will operate your commercial rental truck.
- Get answers to other questions about DOT and FMCSA regulations. Visit the FMCSA's Frequently Asked Questions website and search for compliance-related issues for fleets and drivers by topic.
Penske Makes DOT and FMCSA Compliance Easy
DOT and FMCSA regulations can be tricky to navigate, especially for businesses new to renting. The professionals at Penske will support you across every mile. Not only can you choose vehicles from one of the best-maintained fleets in the industry, but you’ll also get expert guidance on federal and state regulations, along with easy-to-use ELD-compliant tools like the Penske Driver app.
Frequently Asked Questions
Do I need a DOT number for a commercial rental truck?
You may need a DOT number depending on how and where you use a commercial rental truck. A DOT number is required if you are operating across state lines, the truck has a GVWR of 10,001 pounds or more, and/or if you are transporting hazardous materials requiring placards. Be sure to also check the state-specific regulations for every state in which you plan to operate your commercial rental to remain compliant.
What’s the difference between a DOT number and an MC number?
A DOT number enables the U.S. Department of Transportation to track a company’s safety and compliance record. A motor carrier number (MC number, or interstate operating authority) grants authority to transport regulated goods across state lines. Most commercial rentals require only a DOT number. However, for-hire carriers engaging in the interstate transport of federally regulated commodities – such as certain chemicals, food products or household goods – will need an MC number.
Can I keep paper logs for a commercial rental truck or do I need an ELD?
Per the FMCSA, ELDs are required for most commercial truck rentals. Paper logs are only permitted for short-term rentals of eight days or fewer in duration. To stay ELD compliant, Penske offers the Penske Driver app free for all commercial rental customers, allowing drivers to track their hours of service (HOS) and record of duty status (RODS) electronically.