A. The FMCSA has clarified this in an FAQ . From the FMCSA:
There may be instances where the model year reflected on the vehicle registration is not the same as the engine model year, most commonly when a vehicle is rebuilt using a “glider kit.” In this circumstance, an inspector/investigator should use the model year on the engine to determine if the driver is exempt from the ELD requirements. If the engine model year is older than 2000, the driver is not subject to the ELD rule.
Please refer to the FMCSA website or your local DOT department for more details on your specific ELD requirements.
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