Revoked ELDs: Interim Logs, Record Retention and Replacement Deadlines
An electronic logging device (ELD) may still let a driver sign in after it appears on the revoked list. Check the specific official notice with the carrier to determine whether to stop using it and when to replace it. The driver must keep recording daily work and rest while the carrier arranges replacement and preserves the old logs.
These steps address operations subject to the federal ELD requirements. For purely intrastate California operations, check the requirements that apply separately. The driver’s underlying hours-of-service limits continue during replacement.
Match the listing to the device actually in use
Recognizing the brand is not enough. A provider may sell several models, and a notice may cover only one. Ask the carrier to find the following details in the unit or its account.
Device name, model number and software version.
ELD identifier. Use it to identify the specific list entry.
Open the Federal Motor Carrier Safety Administration’s Registered ELDs list and Revoked ELDs list. Compare the details item by item and record the date checked.
Under 49 CFR § 395.22, a motor carrier required to use an ELD must select a device on the registered list. The provider self-certifies the device. Listing is not a government guarantee of product quality.
If the provider says the device has been fixed, check the official list for reinstatement. If it recommends a different product, check the replacement using that device’s own identifying details.
Find the replacement date and arrange interim records immediately
The August 6, 2026 revocation notice, for example, covered the following five devices. The model and registered identifier are given for comparison.
MOONLIGHT ELD. Model MRS, identifier MRS255.
HGRS ELD. Model HGR, identifier HRS169.
HIGHEST ELD. Model HIG4ES, identifier HIG385.
TRUCKFORD ELD. Model TRS, identifier TRS263.
Sparkle ELD. Model PT40SIM, identifier SPARK6.
On September 7, 2026, all five were still on the revoked list. The notice instructed users to discontinue those units, use paper logs or logging software, and replace the devices by October 6, 2026. Drivers were to use the interim recording method while the carrier arranged replacement, instead of continuing normal use until the deadline.
Starting October 6, continued use of these devices was to be treated as operation without an ELD, exposing the driver to out-of-service enforcement. Learning about the notice late did not extend the replacement date. The maximum 60-day arrangement in this notice concerned these devices only. Use the corresponding notice for any other unit.
For these devices before the deadline, the notice recommended that enforcement personnel refrain from citing drivers for no record of duty status (RODS) or failure to use a registered ELD on those grounds. Officers could consult the old display during an inspection. That enforcement recommendation did not guarantee immunity from penalties. Drivers still had to record duty status accurately and comply with hours-of-service (HOS) rules.
Carry hours forward when changing recording methods
On paper or in software, record driving, other work and rest as they actually occurred. Replacing an ELD neither increases available hours nor allows previous time to be erased and the count started over.
Under 49 CFR § 395.8, complete the required date, vehicle, carrier, mileage, location, shipping document and signature information. Use the home terminal’s time standard rather than changing the log with each local time zone. Keep the current log up to date and have the previous seven consecutive days’ records available while on duty for inspection.
Note when the driver switched to paper or software, then check for a gap on either side of that time. Before using logging software, confirm with the carrier how to display the records at roadside. Ordinary logging software can be used for the interim records allowed by the notice. The final replacement ELD still has to be on the official registered list.
Retrieve the old records before ending the service
Download the logs before terminating the old service. Open the files to check that they are complete and readable, and tell drivers where to find the days needed at roadside. They should be able to retrieve the records after the old account is closed.
Do not dispose of records when the service ends. Under 49 CFR § 395.8, the carrier must retain logs and the required supporting documents for at least six months from receipt. Under 49 CFR § 395.22, keep a backup of ELD records on a separate device for six months and protect driver privacy.
Have the driver use the replacement before the next inspection
Select a replacement on the registered list. Before putting it into service, check driver accounts, vehicle details and logging functions. Have the driver practice showing the records and completing a data transfer so the process is familiar at roadside.
Under 49 CFR § 395.22, also carry transfer instructions, malfunction instructions and enough blank logs for at least eight days. Record the actual activation date, verify that replacement occurred by the deadline, and check that the old, interim and new records can be retrieved as one continuous period.
If the device also malfunctions
If an ELD both loses registration and malfunctions, follow 49 CFR § 395.34 for the malfunction. The driver must notify the carrier in writing within 24 hours and reconstruct unavailable records for the current 24-hour period and the preceding seven consecutive days.
The carrier generally must correct the malfunction within eight days of discovering it or receiving the driver’s notice, whichever came first. That is the malfunction deadline. The corresponding revocation notice determines the replacement date for a revoked device.
Disclaimer
This article draws on official FMCSA notices and device lists and the Code of Federal Regulations, checked on September 7, 2026. It provides general information, not legal advice or an individual compliance determination. Device status, notice deadlines and enforcement arrangements can change. Use the current official lists, the specific notice and applicable law. Requirements may differ with the device, operating scope and records. Assess the actual documents and consult the agency or a qualified professional if needed. The author and publisher accept no liability for losses arising from reliance on this article.
Federal Motor Carrier Safety Administration. “FMCSA Removes Five Devices from List of Registered Electronic Logging Devices.” 6 Aug. 2026. https://www.fmcsa.dot.gov/newsroom/fmcsa-removes-five-devices-list-registered-electronic-logging-devices-0. Accessed 7 Sept. 2026.
Federal Motor Carrier Safety Administration. “Registered ELDs.” https://eld.fmcsa.dot.gov/List. Accessed 7 Sept. 2026.
Federal Motor Carrier Safety Administration. “Revoked ELDs.” https://eld.fmcsa.dot.gov/List/Revoked. Accessed 7 Sept. 2026.
United States, Department of Transportation. “49 CFR § 395.22: Motor Carrier Responsibilities—In General.” https://www.ecfr.gov/current/title-49/subtitle-B/chapter-III/subchapter-B/part-395/subpart-B/section-395.22. Accessed 7 Sept. 2026.
United States, Department of Transportation. “49 CFR § 395.34: ELD Malfunctions and Data Diagnostic Events.” https://www.ecfr.gov/current/title-49/subtitle-B/chapter-III/subchapter-B/part-395/subpart-B/section-395.34. Accessed 7 Sept. 2026.
United States, Department of Transportation. “49 CFR § 395.8: Driver’s Record of Duty Status.” https://www.ecfr.gov/current/title-49/subtitle-B/chapter-III/subchapter-B/part-395/subpart-A/section-395.8. Accessed 7 Sept. 2026.