DOT/UCR Registration

Understanding When Trailer Size or Commercial Activities Trigger State & DOT Registration

State

There are many different types of transport trailers for race cars, from enclosed trailers to open tilt decks.  These types of trailers need to be registered with the state department of motor vehicles (DMV) or equivalent agency.  Most states will issue a title, registration and license plates if the trailer is over a certain minimum weight.  Trailers can generally be registered annually, bi-annually or permanently.  Registration fees vary from state-to-state.  The owner must generally certify that a non-commercial trailer is covered by the minimum insurance requirements or pay an uninsured motor vehicle fee.  Trailers are subject to state and federal vehicle safety laws (lighting equipment, reflectors, conspicuity tape, etc.) and state inspection.  See your state DMV for more information. 

Federal

The Federal Motor Carrier Safety Administration (FMCSA) is the agency within the U.S. Department of Transportation (DOT) that regulates non-commercial carriers above a certain weight (safety registration) and commercial shipping operations (safety registration and operating authority for “for-hire” and “non-exempt carriers”).  All interstate and most intrastate carriers register with the FMCSA and are issued a DOT number, a unique identifier that allows the agency to monitor a company or independent owner/operator’s safety management practices and controls.  Any motor carrier that is required to obtain a DOT number is also required to register with the Unified Carrier Registration (UCR). 

Motorsports Exemption:  Are you required to obtain a “DOT” registration for your truck/trailer hauling a race care if crossing state lines?  Not if you fall within the exemption guidelines.  The FMCSA has issued guidance (49 CFR Part 390.3) that states:

§ 390.3: General applicability.

(f) Exceptions. Unless otherwise specifically provided, the rules in this subchapter do not apply to—
(3) The occasional transportation of personal property by individuals not for compensation nor in the furtherance of a commercial enterprise;

Question 21:  Does the exemption in §390.3(f)(3) for the ‘‘occasional transportation of personal property by individuals not for compensation nor in the furtherance of a commercial enterprise’’ apply to persons who occasionally use CMVs [commercial motor vehicles] to transport cars, boats, horses, etc., to races, tournaments, shows or similar events, even if prize money is offered at these events?

Guidance: The exemption would apply to this kind of transportation, provided: (1) The underlying activities are not undertaken for profit, i.e., (a) prize money is declared as ordinary income for tax purposes, and (b) the cost of the underlying activities is not deducted as a business expense for tax purposes; and, where relevant; (2) corporate sponsorship is not involved. Drivers must confer with their State of licensure to determine the licensing provisions to which they are subject.

Commercial Interstate Activities That Require DOT Number:  Commercial entities that operate across state lines are required to obtain a DOT Number if the vehicle/vehicles (truck AND trailer combination) weighs more than 10,000 pounds.  A commercial driver’s license (CDL) is required if the combined vehicle weight is more than 26,000 pounds and the trailer weighs more than 10,000 pounds.  The gross vehicle weight rating (GVWR) is assigned by the manufacturer (weight of the vehicle and cargo carrying capacity) and generally found on a metal plate affixed to the vehicle.  When determining the GWVR of a combination unit, you add together the GVWR of the truck and trailer.  The GVWR is the greater of the actual weight (vehicle and cargo) or the combined GVWR set by the manufacturer(s).

Do I Need One?  You are required to obtain a DOT number if you have a vehicle that:

  • Is used in transporting material found by the DOT to be hazardous and transported in a quantity requiring placarding (whether interstate or intrastate).
    OR
  • Has a gross vehicle weight rating (GVWR) for the combined vehicles, or actual weight for the combined vehicles/cargo of 4,536 kg (10,001 pounds) or more, whichever is greater; or
  • Is designed transport more than 8 passengers (including the driver) for compensation; or
  • Is designed to transport more than 15 passengers, including the driver, even if not used to transport passengers for compensation;
  • AND is involved in “interstate commerce,” which is defined as:
    Trade, traffic, or transportation in the United States—
  • Between a place in a State and a place outside of such State (including a place outside of the United States)
  • Between two places in a State through another State or a place outside of the United States; or
  • Between two places in a State as part of trade, traffic, or transportation originating or terminating outside the State or the United States.

Unified Carrier Registration (UCR):  Any motor carrier that is required to obtain a DOT number is required to register with the UCR and pay fees.  This includes private carriers and for-hire carriers.  (Examples would include owners taking their car to the track if the activity could be considered “commercial” or a person hired by the owner to take the race car to the track.)  The current fee for 1-2 vehicles is $76/year.  For purposes of the UCR, a “vehicle” has a powertrain.  It does not apply to the trailer.  The UCR is a federal program administered by the states, so the paperwork will be completed according to the state’s rules.  A few states do not participate in the UCR program, in which case the vehicle must be registered in a state that does participate in the UCR.  Everyone may use the national UCR website to start the registration process.  The site is hosted by Indiana.  Since the UCR application will be based on your DOT MCS-150 registration, wait 24 hours for the DOT registration to be processed.  For more information:  https://www.ucr.in.gov/ucrHome.html

“Vehicle” Includes Pick-Up Trucks? Yes.  The definition of “vehicle” and “vehicle combination” does not distinguish between types, so a pick-up truck with a 26-foot box or open trailer, or a toter home/trailer combination are all covered.  It is simply based on weight and whether the activity is commercial.

What is the difference between interstate carriers and intrastate carriers? Interstate carriers operate vehicles that are authorized to operate across state and country borders. Intrastate carriers operate entirely within a single state. 

States That Require DOT Number for Commercial Intrastate Activities:  Currently, 33 states require registrants of “commercial” motor vehicles to obtain a DOT Number even if they do not cross state lines.  As of August 2015, these states include: Alabama, Alaska, Arizona, Colorado, Connecticut, Florida, Georgia, Indiana, Iowa, Kansas, Kentucky, Maine, Maryland, Michigan, Minnesota, Missouri, Montana, New Jersey, New York, Nebraska, North Carolina, Ohio, Oklahoma, Oregon, Pennsylvania, South Carolina, Tennessee, Texas, Utah, Washington, West Virginia, Wisconsin and Wyoming.  States that do not have a DOT-registration requirement for in-state “commercial” motor vehicles may have established their own state-based system.  If you obtain a DOT number, you don’t need a state number – it is just one or the other.  DOT numbers must be displayed with your name or business name and be visible from 50 feet away.  It must be posted on vehicle used to tow the trailer (not the trailer) in a contrasting color.  

Note: a few states may permit out-of-state use once or twice a year for limited duration via a “trip permit” from the state in which it is registered

Click here for more information or to obtain a DOT number:

Frequently Asked Questions & Useful Tips 

  • What is the definition of “commercial”? An exchange of goods or services for money and in-kind exchanges can be viewed as commercial.  For example, one begins to enter the commercial world when a racing activity includes prize winnings, a car part or other discounted or free items have been given in exchange for displaying the sponsor company’s logo on the trailer or race car.  Hauling someone else’s vehicle could also be construed as a commercial activity.
     
  • Proving Activities are Non-Commercial:  While the FMCSA provides a clear-cut exemption from DOT registration, it is also very specific: (1) prize money must be declared as ordinary income for tax purposes, and (2) the cost of the underlying activities may not be deducted as a business expense for tax purposes; and(3) corporate sponsorship cannot be involved.  However, the state police officer questioning your trailer won’t have a copy of your tax return to confirm that you declared the winnings as ordinary income and didn’t attach a Schedule C business return.  They will only be looking for visual clues that would raise suspicion.  For example, your trailer includes a business-type name (“Joe Brown Racing”), the vehicle within the trailer or on top of an unenclosed trailer is covered with corporate logos, or the racing event has widely-advertised winnings.  The police officer may decide to issue a ticket and let you convince the judge that you are non-commercial.  Some people put words such as “PRIVATE - NOT FOR HIRE” on the trailer.  It has no legal meaning but may help discourage the officer from making a stop.      
     
  • Conflicting IRS/DOT Definitions of “Commercial”: The Internal Revenue Service (IRS) and FMCSA are two unrelated government agencies with separate rules governing the definition of “commercial.”  The IRS may challenge a racer seeking to claim expenses as Schedule C business expenses if the activity does not produce a profit for three out of five years.  When challenged (i.e., audited), the IRS may deem it to be a hobby.  As noted, the FMCSA has its own method for defining “commercial” activities.  Sometimes the two definitions are in conflict (ex: FMVCSA deems the activity to be commercial based on corporate sponsorship but the IRS deems it to be noncommercial because not producing a profit).
     
  • Motor Homesregistered as “recreational vehicles” (RV license plate) cannot be used in the furtherance of a commercial operation. If the motor home is part of the commercial operation, it will likely need to be registered as a truck or similar classification.·         
     
  • 10,001 Pound Ramifications:  “Commercial” motor vehicles at this weight range must comply with a range of federal responsibilities and state responsibilities for intrastate activities.  They include a medical card, log book, commercial insurance, fire extinguisher, reflective road triangles, spare fuses, pre-trip and post-trip driver inspections, stopping at weigh stations, etc.  The trucks and trailers are also subject to an annual safety inspection.      
     
  • 26,001 Pound Ramifications:  The 26,001 pound threshold triggers Commercial Driver’s License (CDL) and Drug and Alcohol Testing requirements.  State governments are responsible for issuing CDLs, not the FMCSA.  A CDL is required for anyone driving the vehicle, not just the owner.  Failure to have a CDL is the same as driving without a license.
    For more information: https://www.fmcsa.dot.gov/registration/commercial-drivers-license
    For specific CDL state laws: http://www.cdlresources.org/state_law.htmlor http://www.drivinglaws.org/topics/commercial-driving-laws-cdl   
     
  • Medical Certificate:  The “commercial” vehicle or combination has a GVWR of 10,001 lb. or more.  Do I need a medical examiner's certificate?  Yes. The medical qualification and exam requirements apply to all drivers of “commercial” vehicles. You may download the medical exam form here. http://www.fmcsa.dot.gov/registration-licensing/print-forms/print-forms.htm·         
     
  • Hours of Service:  The “commercial” vehicle has a GVWR of 10,001 lb. or more.  What hours-of-service limits apply?  The driver may currently drive up to 11 hours within a 14-hour time period.  The driver must then take at least 10 consecutive hours off duty.  You must maintain a Drivers Hours of Service Log Book if you are traveling more than a 100 mile air radius from your base location. 
     
  • What are common violations for vehicles and combinations with GVWR of 10,001 lbs. or more
    Improper vehicle identification marking (Name and US DOT Number)
    No medical exam certificate
    No fire extinguisher
    No stopped vehicle warning devices (reflective triangles)
    Driver exceeded hours-of-service limits
    No time records kept on driver
    No annual mechanical inspection of vehicle
    Driver did not do a pre-trip inspection (need not be written)
    Trailers not equipped with required brakes, lights and reflectors
    Using a radar detector (if prohibited)

Fuel:  Tickets have been issued for transporting fuel within a state or across state lines in a non-DOT compliant portable fuel container or a non-compliant fuel tank. The tickets are usually for hazardous materials violations but may also be for loss of state revenue (fuel tax).  There may be limits on the amount of fuel that can be transported (ex: four cans per vehicle in properly labeled five gallon containers) and for fuel cells that are not DOT compliant.  Check with your state for more information as state laws vary.  

Does the trailer need brakes?  Yes, if the gross weight of the trailer (weight of trailer and load) is over 3,000 lbs.  Required brakes are operative service brakes on all wheels, a parking brake system, an emergency brake system, and a breakaway braking system. The parking and emergency systems can be combined.

What is the International Registration Plan (IRP) & International Fuel Tax Agreement (IFTA)? The IRP applies to truck fleet operations.  It applies only to the largest commercial motorsports operations, not individual enthusiasts taking their race car to the track.  The IRP and IFTA are reciprocal agreements for registering commercial motor vehicles and truckers, tracking mileage and calculating fuel taxes to be distributing proportionately amongst the states.  The registrant must meet the following: (1) vehicle taken out of its home state; (2) vehicle/trailer combination has a GVWR of 26,000 lbs or more; and (3) vehicle/trailer used primarily for transport of property.  For more information: www.irponline.org

Federal Length RequirementsUnless a longer truck-semitrailer combination was in use in a state on June 1, 1991, the maximum overall length on the National Network (interstates and major highways) is 65 feet.  A few states have combination lengths that exceed the 65 foot limit and conflict with federal law.  No state shall impose a limitation of less than 46 feet on the distance from the kingpin to the center of the rear axle on trailers or semitrailers used exclusively or primarily to transport vehicles in connection with motorsports competition events.  

For more information about the Motor Carrier Regulations:  

What to do if stopped by the police? Be polite, respectful, respond to requests and avoid being argumentative.  A police officer is more likely to respond favorably if you demonstrate that you are making an effort to comply with the laws/regulations for that state.

State Resources 

 

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