Revoked ELDs: Interim Logs, Record Retention and Replacement Deadlines

California fleets subject to federal electronic logging device requirements should check the applicable FMCSA notice when an ELD registration is revoked. A device that still displays hours may require replacement. Intrastate-only operations need a separate applicability review.

Match the device name, model, software version and ELD Identifier against FMCSA's registered and revoked lists. Registration reflects manufacturer self-certification, not government endorsement. Verify official reinstatement rather than relying on a provider's repair promise.

For the five devices in FMCSA's August 6, 2026 notice, replacement must be completed before October 6, 2026. Beginning October 6, continued use is treated as operating without an ELD and triggers the notice's out-of-service enforcement instructions. Other batches have their own notices; deadlines do not restart when a driver learns about revocation.

The August notice directs affected users to discontinue the revoked devices and use paper logs or logging software. Its limited enforcement guidance does not excuse other violations. Keep accurate, continuous duty records and follow hours-of-service limits. Use the home terminal's time standard, update current logs and retain the previous seven consecutive days for inspection while on duty. Changing devices does not reset hours.

Before ending the old service, secure readable historical records. Under 49 CFR 395.8, carriers retain required logs and supporting documents for at least six months from receipt. Section 395.22 separately requires six months of ELD backup records on another device, with driver privacy protected.

Actual malfunctions follow section 395.34, including written notice within 24 hours and the general eight-day correction requirement. These are not substitute revocation deadlines.

Confirm the replacement's registration, account details and log functions. Provide required transfer and malfunction instructions plus at least eight days of blank logs. Have drivers practice presenting and transferring records before use. Follow current official notices and seek qualified advice for individual compliance questions.